A wealth of experience based on a number of cases.

Case 1:

How should I implement all those complex laws and regulations into my organisation?

The challenge

An online bank was confronted with the introduction of complex and highly detailed investment services legislation (MiFID 2). It wanted to know how it could best implement this complex legislation within its organisation.

The solution

Finnick has opted for a practical and result-driven approach. In doing so, not only the text of the law but in particular the purpose of the legislation (investor protection) was considered. Did the investment proposition still meet customer needs? This has resulted in a change in the investment proposition. Finnick has drawn up a clear implementation plan with concrete action points, so that everyone in the organisation knew what to do. Clear and simple communication with customers was essential, so that customers understood what was going to change.

The result

Thanks to a clear action plan, clear communication and a result-driven approach, we succeeded in implementing the legislation in the organization on time. Because the changed investment proposition was more in line with the knowledge, experience and objectives of the customers, this also resulted in more satisfied customers.

Case 2:

An efficient negotiation process with a good result

The challenge

An online bank noticed that its clients needed alternative investment options in addition to its existing investment services. It wanted to respond to this by launching a new crowdfunding product, for which it wanted to cooperate with a crowdfunding platform. But it lacked knowledge and experience of crowdfunding. How could the bank create a good crowdfunding product with clear mutual agreements in a short period of time?

The solution

Finnick first performed an extensive due diligence to determine whether the crowdfunding platform could offer a product that could meet the bank’s (quality) requirements. This resulted in a concrete list of points for improvement, so that both parties knew what was needed to make the partnership successful. Based on this, a partnership agreement was drawn up with clear agreements about the mutual roles and responsibilities, as well as customer documentation.

The result

As a result of the extensive due diligence and a clear action plan with concrete points for improvement, both parties knew where they stood. As a result, it turned out to be possible to quickly make clear and concrete agreements in a partnership agreement and launch a successful crowdfunding product on the market.

Case 3:

How do I gain insight into complex supervisory laws and regulations?

The challenge

After the introduction of new legislation for payment services (PSD 2), there was a great deal of uncertainty in the market about the scope of the new legislation. Did this new legislation only apply to online payment accounts or also to online savings accounts from which payment and withdrawal transactions may be made solely by means of a current account? In the latter case, implementing the new legislation would entail significant extra time and costs.

The solution

Contact has been sought with various market parties in order to determine a joint position in mutual consultation. This resulted in a position paper that was discussed jointly with the Dutch supervisor (DNB), emphasizing the importance of clarifying this issue for the market quickly.

The result

In response to the concerns expressed, DNB eventually sought consultation with European supervisors. This resulted in a written position from the European Commission in which the joint position of the various market parties was endorsed. This created a ‘level playing field’ for payment services at European level.

Case 4:

How do I meet the requirements set by the supervisor?

The challenge

In response to new legislation for investment services (MiFID 2), the Dutch Authority for the Financial Markets (AFM) sent a letter to the sector expressing its expectation that investment advertisements would be reviewed based on the new legislation. An investment firm wanted to know how it could ensure that it met the supervisor’s expectations.

The solution

First, the process of creating investment advertisements was analysed. It soon became apparent that the advertising rules were not clear enough to everyone. Therefore, an advertising policy was drawn up with examples of client communications that are allowed/not allowed and of ‘best practices’. Arrangements were also made with the departments involved for dividing work and mutual responsibilities. Finally, internal training sessions were held on the new advertising policy.

The result

By reviewing the entire process for creating investment advertisements, it was possible to arrive at an integrated approach. Everyone now has clarity about what is expected of him/her and what legal framework applies. As a result, the quality of investment advertising has improved across the board, while the investment firm has greater control over compliance with advertising legislation.

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