A wealth of experience revealed in a number of cases.

Case 1:

New legislation also creates opportunities.

The challenge

An online bank had to introduce complex and highly detailed investment services legislation (MiFID 2). It wanted to know how it could best implement this legislation in its organisation.

The solution

Finnick did not limit itself to an impact analysis and implementation plan, but  also looked at whether the bank’s investment services still catered for the client’s needs. This led to a change in investment services from ‘execution-only’ services to portfolio management, making life easier for clients as the bank took over making the investment decisions.

The result

Partly due to a thorough impact analysis and a concrete and to-the-point implementation plan, it was possible to introduce the new investment proposition on time. A clear communication plan resulted in the vast majority of clients agreeing to the change in services. The bank not only complies with the new legislation, but it now also has an improved service and satisfied clients.

Case 2:

Together you are stronger and achieve more.

The challenge

An online bank noticed that its clients needed alternative funding options to its existing investment services. It wanted to respond to this by launching a new crowdfunding product. But it lacked knowledge and experience of crowdfunding.

The solution

After an extensive market analysis, it was decided to market a new proposition with an existing crowdfunding provider. An extensive due diligence was conducted to establish that the bank’s quality requirements were met. This allowed the bank to safeguard its reputation and promptly identify any obstacles.

The result

Because of the extensive due diligence and a clear plan of action with concrete points for improvement, both parties knew where they stood. This made it possible to quickly reach clear and concrete arrangements in a cooperation agreement and to market a successful crowdfunding product within a short timeframe.  

Case 3:

Lobbying to achieve the desired result.

The challenge

After new legislation for payment services (PSD 2) was introduced, there was much uncertainty in the market about the scope of this new legislation. Did it apply only 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

Various market participants were contacted in order to agree on a common position. This led to a ‘position paper’ that was jointly discussed with the Dutch Central Bank (DNB), emphasising the importance of clarifying this issue quickly for the market.

The result

In response to the concerns raised, DNB eventually sought consultations with European regulators. This led to a written position from the European Commission endorsing the various market participants’ joint position. This created a ‘level playing field’ for payment services at European level.

Case 4:

What a letter from the regulator can bring about.

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 regulator’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. Lastly, 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 frameworks apply. 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.