A 2001 International Monetary Fund (IMF) Financial System Stability Assessment (FSSA) indicates that Finland has, in general, put in place the essential conditions for effective banking supervision in most areas and that they are being administered satisfactorily. The FSSA, however, notes that Finland is materially non-compliant with some of the Basel Core Principles (BCPs) for Effective Banking Supervision. These pertain to the weaknesses in the power of the Finnish Financial Supervision Authority (FIN-FSA) to: require compliance with safety and soundness measures; assess the adequacy and prescribe levels of loan-loss provisioning; control connected lending; establish criteria for acquisitions and investments; establish capital requirements based on risk; conduct more proactive on-site and off-site supervision; and take prompt remedial action. Finland is also found lacking in the areas of clear objectives, autonomy, and resources of the supervisor. A more recent (2007) IMF Article IV report nevertheless affirms that the Finnish financial system is sound and stable. The report mentions the planned merger of the FIN-FSA and the Insurance Supervisory Authority in 2009, which is designed to pool the expertise and resources of the former supervisors and bring common supervised cross-sector entities under one umbrella, thereby making supervision more effective. Despite the 2001 IMF assessment and subsequent reports, there is little information publicly available directly addressing Finland's overall compliance with the BCPs.

General Overview

The 2007 IMF Article IV consultation report affirms that the Finnish financial system is "sound and well-supervised" (p. 15), and that the banks are profitable, with high capital adequacy ratios and continuing growth in profits. Also, the system can withstand severe shocks. However, the report does point to the challenges to regulation and supervision from cross border contagion, and recommended more "cooperation with market participants and foreign supervisors... to minimize systemic risks from cross-country activities" (p. 1). The report states that the Finnish supervisors -- the Bank of Finland (Suomen Pankki, or BoF) and the FIN-FSA (which is part of the BoF) -- recognize the challenges posed by cross-border institutions, especially in crisis situations, and have focused their efforts at the European Union (EU) and Nordic countries' (comprising Denmark, Finland, Iceland, Norway, and Sweden) levels to harmonize supervision of cross-border groups, define intervention rules and procedures in contingency situations, and to coordinate efforts with market participants and foreign supervisors. The report also talks about the planned merger of the FIN-FSA and the Insurance Supervisory Authority (Vakuutusvalvonta, or ISA) in 2009. This is designed to pool the expertise and resources of the former supervisors and bring common supervised cross-sector entities under one umbrella, thereby making supervision more effective. The report finds that Finland is keeping pace with the EU Directives. The EU capital requirements directive and the 2006 amended EU Markets in Financial Instruments Directive (MiFID) came into effect in 2007.

The 2001 IMF FSSA finds that "the essential conditions for effective bank supervision have in general been put in place, and for the most part are being administered satisfactorily" (p. 35). According to the FSSA and the Ministry of Finance (MoF) website, the authority to formulate laws and issue licenses in the financial sector rests with the MoF and, per the FSSA, the prudential supervisory authority lies with the FIN-FSA, an autonomous agency established in 1993. Finland has a stable and well-developed institutional and legal infrastructure for supervision. However, it does not have a law on cross-sector and cross-border financial conglomerates to reflect the needs of the times. The FIN-FSA and the ISA have entered into a cooperation agreement on this issue, however, and Finland has signed protocols with pan-Nordic supervisors. Finnish legislation on financial conglomerates, the Act on the Supervision of Financial and Insurance Conglomerates, was put in place in July 2004.

The FSSA, however, notes that Finland is "materially non-compliant with certain essential criteria" (p. 35) of the Basel Core Principles (BCPs) for Effective Banking Supervision. These pertain to the weaknesses in the FIN-FSA's powers to (1) require compliance with safety and soundness measures; (2) assess the adequacy and prescribe levels of loan loss provisioning; (3) control connected lending; (4) establish criteria for acquisitions and investments; (5) establish capital requirements based on risk; (6) conduct more proactive on-site and off-site supervision; and (7) take prompt remedial action. Finland is also found lacking in the areas of clear objectives, autonomy and resources of the supervisor.

The 2006 FIN-FSA annual report (published in 2007 and hereafter referred to as the 2007 FIN-FSA report) states that the financial markets and entities operating therein are supervised by the FIN-FSA. The entities include banks, investment firms, fund management companies and the stock exchange. Further, the Act on the Financial Supervision Authority governs the supervisory role and objectives of the FIN-FSA, which are to ensure financial stability and maintain public confidence in financial markets. The report further states that the core responsibilities of the FIN-FSA comprise supervision and regulation. As a prudential supervisor, the FIN-FSA assesses the financial position, risk taking capacity, and risk management policies and procedures of supervised institutions. As a financial sector regulator, the FIN-FSA issues standards and participates in the drafting of financial legislation at the national and EU level.

The 2007 "Global Survey" report by the Institute of International Bankers (IIB) states that, in response to financial restructurings, the Finnish Bankers' Association, the Federation of Finnish Insurance Companies, the Finnish Finance Houses Association, and the Employers' Association of Finnish Financial Institutions merged in 2007 to become the Federation of Finnish Financial Services.

The Principles

1. (1) Clear responsibilities and objectives for each supervisory agency.

II

According to the 2001 IMF FSSA, the authority to formulate laws and issue licenses in the financial sector rests with the MoF, whereas the prudential supervisory authority lies with the FIN-FSA, an autonomous agency established in 1993 as an administrative part of the BoF. There are clear legislative documents prescribing the duties and responsibilities of the FIN-FSA. The FIN-FSA is overseen by the Parliamentary Supervisory Council (PSC). Finland has a stable and well-developed institutional and legal infrastructure for supervision. However, it does not have a law on cross-sector and cross-border financial conglomerates to reflect present-day requirements. The FIN-FSA and the ISA have entered into a cooperation agreement on this issue, however, and Finland has protocols signed with pan-Nordic supervisors. Finnish legislation on financial conglomerates was put in place in July 2004 (Act on the Supervision of Financial and Insurance Conglomerates). However, there is little information publicly available addressing Finland's compliance with this principle.

Areas of weakness with regard to this principle, as observed by the FSSA, are: (1) the objectives as detailed in its annual reports are not clearly aligned with other explanatory material; and (2) the distribution of banking supervisory authority and responsibility between the FIN-FSA and the MoF is complex and unclear. Enforcement is not in the hands of the FIN-FSA, and the scope of its enforcement powers is not transparent. The IMF therefore recommends that Finland "develop a structure (possibly a manual/compendium) for the body of law and regulation for banking supervision that reflects the structure of the supervisory framework, and the objectives and principles that underpin it" (p. 39).

The FIN-FSA's website provides information on its supervisory responsibility. It supervises financial markets and their participants. Its objective is to ensure financial stability and public confidence in the financial markets under the Act on the Financial Supervision Authority. Supervision, according to the website, is carried out on a statutory basis, and the spheres include the financial positions, risk-bearing capacity, risk management, and code of conduct of banks, investment firms, management companies, stock exchange, and other financial institutions except the insurance companies. The FIN-FSA undertakes regulation as a core activity in addition to supervision, its objective being flexibility and accountability. The FIN-FSA's regulatory framework is principle-based rather than rule-oriented.

1.(2) Operational independence and adequate resources.

II

There is little information publicly available as to Finland's compliance with this principle. The 2001 IMF FSSA, however, notes that the FIN-FSA is an independent supervisory authority within the BoF charged with the supervision of financial markets and their participants. The FSSA further notes that the FIN-FSA was subject to the oversight of the Parliamentary Supervisory Council (Eduskunnan Pankkivaltuusto, or PSC) only in respect of administrative matters, not in respect of the effectiveness of its supervision. However, the FSSA finds that the FIN-FSA "has limited independence and accountability" (p. 35). This is because, the MoF has the authority to grant or revoke the license of institutions. In this regard, the 2007 FIN-FSA report states that credit institutions are granted authorization to operate by the FIN-FSA, which also has the authority to revoke authorization if the entity does not meet requirements for authorization. Per the 2001 FSSA, the FIN-FSA is not supervised by any prescribed agency as to its effectiveness and propriety. In this regard, the FSSA recommends that the PSC -- which oversees the administration of the FIN-FSA -- be charged with the responsibility of overseeing the FIN-FSA's supervisory effectiveness. Finland is also found lacking in the area of resources of the supervisor.

The 2007 FIN-FSA report states that the FIN-FSA is funded by the supervisory and processing fees it levies on supervised entities and securities issuers. Further, although the FIN-FSA is administratively connected to the BoF, it is independent in its decision-making. Its governance and management is governed by the Act on the Financial Supervision Authority, which requires the operations and decision making of the FIN-FSA to be transparent and its management and governance to be sound. However, the FIN-FSA is supervised on operational and administrative matters by the PSC, elected by the Finnish Parliament. The Council also has a say in the appointment of the Board of the FIN-FSA.

1.(3) A suitable legal framework for authorization and ongoing supervision.

II

According to the 2001 IMF FSSA, "the general prerequisites for adequate supervision are largely in place" (p. 23). Further, Finland has a stable and well-developed institutional and legal infrastructure, facilitating effective supervision. The Finnish Constitution contains the general principles governing the financial system's legal framework. Finland also has a codified legal system. In addition, the EU legal framework has an important bearing on Finnish supervisory laws. The FIN-FSA is charged with the responsibility to ensure that the supervised entities operate in accordance with relevant acts, especially the Act on Credit Institutions and its associated decrees, FIN-FSA guidelines and regulations, and those of other authorities. However, the FSSA finds that Finland does not have a law on cross-sector and cross-border financial conglomerates to reflect the needs of the time. Finnish legislation on financial conglomerates was put in place in July 2004 (Act on the Supervision of Financial and Insurance Conglomerates). The 2007 FIN-FSA report states that the credit institutions are granted authorization to operate by the FIN-FSA, which also has the authority to revoke authorization if the entity does not meet the requirements for authorization. Despite the above information, there is little in terms of publicly available information that directly addresses Finland's compliance with this principle.

1.(4) A suitable legal framework to address compliance with laws as well as safety and soundness concerns.

NC

The 2001 IMF FSSA notes that Finland is "materially non-compliant with certain essential criteria" (p. 35) of the Basel Core Principles. One of these pertains to the weaknesses in the FIN-FSA's powers to require compliance with safety and soundness measures. The IMF notes that the FIN-FSA has communicated to the MoF a list of powers it needs to be added to its portfolio and has seen an expansion of its authorization and supervisory powers. There is however little further information as to whether this expansion encompasses the requirements of this principle. The FSSA further notes that the FIN-FSA uses moral suasion to ensure compliance with safety and soundness concerns, and recommends that the FIN-FSA also be given the power and discretion to apply disciplinary measures to remedy safety and soundness as well as other regulatory shortcomings in institutions.

1.(5) Legal protection for supervisors.

II

The 2001 IMF FSSA notes that the officers of the FIN FSA have the same legal protections as the members of the civil service, and that these protections "appear broadly adequate" (p. 39). The IMF also asks Finland to "consider whether [the legal protections] are adequate for the particular liabilities that might arise in connection with the conduct of a banking supervision function" (p. 40). The 2007 FIN-FSA report states that the staff of the FIN-FSA has the ethical requirements to be loyal and independent in their conduct and activities. However, there is little information publicly available as to Finland's compliance with this principle.

1.(6) Arrangement for sharing of information between supervisors and protection of confidentiality of shared information.

II

The FIN-FSA website declares that it has extensive cooperation arrangements with other domestic supervisors, including the BoF, the MoF, the ISA, and the Ministry of Social Affairs and Health (MSAH). Further, the FIN-FSA cooperates on the international front, participating in international fora, especially at the EU level, with such organizations as the Committee of European Banking Supervisors (CEBS), the Groupe de Contact (the banking supervisors' cooperation division under the CEBS), and the Banking Supervision Committee (BSC) under the European System of Central Banks (ESCB). In addition, it cooperates directly with the supervisory authorities of other countries, especially the Nordic and other EU countries on the basis of specific supervisory memoranda of understanding (MoUs). The 2006 BoF annual report (published in 2007) notes that the BoF undertook joint stress tests in the banking and insurance sectors with the FIN-FSA and the ISA in 2006. It also signed a MoU with the FIN-FSA in March 2006 to enhance cooperation and information sharing to handle financial sector emergencies and manage risks. Further, it participates in various working groups relating to financial sector regulation and supervision. For instance, it is involved with the MoF working group on the implementation of the MiFID and a joint working group involving the BoF, the MoF, the FIN-FSA, the ISA, and the MSAH on the deepening financial market integration and the challenges to the Finnish financial sector. Despite all the above information, however, there is little information publicly available addressing Finland's actual compliance with this principle.

In terms of international cooperation, the 2006 BoF annual report states that the BoF signed a MoU with the Swedish central bank in January 2006 to coordinate financial sector oversight. The BoF also participates in joint EU and Eurosystem crisis management exercises conducted by the respective central banks and supervisors. The BoF is also on the major international committees and institutions relating to financial market operations and supervision, including the ESCB and the European Commission's (EC) working groups on the creation of the Single Euro Payments Area (SEPA) and the second generation Trans-European Automated Real-time Gross Settlement Express Transfer System (TARGET2). Additionally, the BoF collaborates with the Nordic-Baltic countries on matters of financial market integration and infrastructure.

2. Clearly defined permissible activities for banks and control of the use of the word 'bank'.

II

There is insufficient information publicly available addressing Finland's compliance with this principle.

3. Criteria for structure, directors, operating plan, controls, financial condition and capital base.

II

The 2001 IMF FSSA finds that although the FIN-FSA has issued a guideline on fit and proper requirements, the regulations on the fitness and propriety of directors and the senior management are not binding. Apart from the above statement by the IMF, there is little further information publicly available addressing Finland's actual compliance with this principle.

4. Authority to review and reject transfer of ownership.

II

There is insufficient information publicly available that directly addresses Finland's compliance with this principle.

5. Authority to review major acquisitions and investments.

NC

The 2001 IMF FSSA notes that Finland is "materially non-compliant with certain essential criteria" (p. 35) of the Basel Core Principles. One of these pertains to the weaknesses in the FIN-FSA's powers to establish criteria for acquisitions and investments, and the absence in the Act on Credit Institutions of explanation pertaining to the criteria on acquisitions and investments. The IMF recommends the FIN-FSA to establish regulations defining acquisitions and investments that require supervisory approval. The IMF, however, notes that since the FSSA, the FIN-FSA communicated to the MoF a list of powers it needed to be added to its portfolio, and has seen an expansion of its authorization and supervisory powers. There is little further information as to whether this expansion encompasses the authority to review major acquisitions and investments.

6. Minimum capital adequacy requirements (meet Basle Capital Accord for internationally active banks).

II

The 2001 IMF FSSA finds that the 1993 Act on Credit Institutions, with amendments up to 2001, allowed credit institutions to use credit loans as tier-one capital with no minimum term or a period of notice. Also, as of 2001, the FIN-FSA did not have the power to require higher risk institutions to have a minimum capital ratio in excess of the 8 percent requirement. The 2007 IMF report states that the EU Capital Requirements Directive based on Basel II has been effective in Finland since February 2007, but that the banks can delay applying it until 2008. The FIN-FSA has asked the banks applying the risk-based approach prescribed by Basel II to keep their capital levels at the levels required under Basel I. Nonetheless, there is insufficient information publicly available as to Finland's compliance with this principle.

The 2007 IIB Global Survey report states that under the 2007 Act on Credit Institutions, all supervised credit institutions are required to report to the FIN-FSA without delay if their consolidated funds fall below the minimum requirement as prescribed under the new law. In this circumstance the FIN-FSA determines the timeframe within which the shortfall has to be met. If the credit institution fails to meet the fund requirement in that period, the FIN-FSA may withdraw authorization. The FIN-FSA also has the authority to enforce Pillar 2 requirements on supervised entities or their consolidated groups, which may amount to more than the 8 percent required by Basel I for a period of at the most 3 years.

7. A method exists for the evaluation of procedures related to loans, investments and portfolio management.

II

The 2001 IMF FSSA notes that the FIN-FSA reviews and assesses the credit procedures and loan loss provisions of institutions during its on-site inspections. However, it does not have the statutory authority to "require a credit institution to strengthen its lending practices, credit-granting standards, and level of provisions and reserves if it deems the level of problem assets to be of concern" (p. 36). The IMF therefore recommends that the FIN-FSA be given such statutory authority. Nonetheless, there is insufficient information publicly available as to Finland's compliance with this principle.

8. Policies, practices and procedures for evaluating the quality of assets and the adequacy of loan loss provisions and reserves.

II

The 2001 IMF FSSA notes that the FIN-FSA reviews and assesses the credit procedures and loan-loss provisions of institutions during its on-site inspections. However, it does not have the statutory authority to "require a credit institution to strengthen its lending practices, credit-granting standards, and level of provisions and reserves if it deems the level of problem assets to be of concern" (p. 36). The IMF therefore recommends that the FIN-FSA be given such statutory authority. The FSSA further finds that the 1993 Act on Credit Institutions, with amendments up to 2001, allowed credit institutions to use credit loans as tier-one capital with no minimum term or period of notice. Also, as of 2001, the FIN-FSA did not have the power to require higher risk institutions to have a minimum capital ratio in excess of the 8 percent requirement. Nonetheless, there is insufficient information publicly available as to Finland's compliance with this principle.

9. Prudential limits and management information system on concentration of exposure.

II

There is insufficient information publicly available that directly addresses Finland's compliance with this principle.

10. Arm's length rule and monitoring for connected lending.

II

The 2001 IMF FSSA recommended that Finland amend the then effective Act on Credit Institutions to include the stipulation that connected lending and lending to related parties be not extended on more favorable terms than business-as-usual loans. The FSSA also calls for explicit powers to the FIN-FSA as provided in the Act on Credit Institutions, to limit connected lending, include the statistics on connected lending when deducing capital adequacy, and require collateralization of such loans. As the FSSA found that there were no reporting requirements related to aggregate connected lending, it also recommended establishing such requirements. However, there is insufficient information publicly available as to Finland's compliance with this principle.

11. Policies and procedures for country risk and transfer risk.

II

The 2001 IMF FSSA notes that the FIN-FSA does not have supervisory oversight requiring a credit institution to set provisions that commensurate to country or transfer risk. However, there is insufficient information publicly available as to Finland's compliance with this principle.

12. Measuring and monitoring market risk. Limit and/or specific capital charge on market risk exposure.

II

There is insufficient information publicly available that directly addresses Finland's compliance with this principle.

13. Comprehensive risk management processes.

II

The 2001 IMF FSSA finds that the FIN-FSA does not appear to have adequate powers to require the supervised entities to strengthen their risk management systems, and therefore recommends that its power be expanded to include this authority. However, there is insufficient information publicly available as to Finland's compliance with this principle.

14. Adequate internal controls.

II

The 2001 IMF FSSA finds that the size and composition of the Board of Directors and senior management of credit institutions are beyond the legal scope of the FIN-FSA and the MoF. There is no explicit requirement in law for the institutions to inform supervisors or seek their permission when there are material changes in their activities, except where the entity falls below the 8 percent minimum capital ratio. The FSSA, therefore, calls for a legal basis for the FIN-FSA's power to require changes in the board or management to reflect the size and nature of the activities of the supervised institutions. However, there is insufficient information publicly available as to Finland's compliance with this principle.

The 2007 FIN-FSA report states that the FIN-FSA's prudential regulation proactively identifies risks threatening financial stability and, as such, focuses on internal control and risk management systems of supervised entities to ensure that they have sufficient financial and other resources to fund their operations and that they do not take too much risk vis-à-vis their capital buffers.

15. Strict "know-your-customer" rules and high ethical and professional standards.

II

The FIN-FSA website states that the Finnish anti-money laundering and combating the financing of terrorism legislation is based on EU directive on Money Laundering and the FATF recommendations, and is formulated by the Ministry of the Interior. The FIN-FSA supervises the risk management practices and internal controls to prevent money laundering in supervised institutions. Supervised entities are required to identify and know their customers and to detect and report suspicious transactions or activities to the Money Laundering Clearing House (MLCH), the Finnish FIU, which is a part of the National Bureau of Investigation in the Finnish Police. However, there is insufficient information publicly available as to Finland's compliance with this principle. A 2007 report by the Financial Action Task Force (FATF) indicates that Finland is largely compliant with the FATF's recommendation on suspicious transaction reporting (STR), and only partially compliant with recommendations relating to customer due diligence and internal controls for banks.

16. Effective supervisory system consisting of on-site and off-site supervision.

II

The 2001 IMF FSSA finds that the supervisory methodology was in transition in 2001, and recommends the FIN-FSA to make use of an effective balance of on and offsite assessment techniques and practices" (p. 37). However, there is insufficient information publicly available as to Finland's compliance with this principle.

17. Regular contact with bank management and understanding of bank's operations.

II

There is insufficient information publicly available that directly addresses Finland's compliance with this principle.

18. Analytical reports and statistical returns on solo and consolidated basis.

II

The 2001 IMF FSSA finds that, the FIN-FSA "has not established criteria to assess the work of internal audit and therefore it is difficult for the FIN-FSA to come to an opinion on whether a reliance process was reasonable" (p. 37). However, there is insufficient information publicly available as to Finland's compliance with this principle.

19. Independent validation of supervisory information through on-site examination or external auditors.

II

The 2001 IMF FSSA finds that the FIN-FSA does not enforce its statutory power to review external audit working papers, and recommends tighter enforcement for a "productive reliance process" (p. 37) with the external auditors. However, there is insufficient information publicly available as to Finland's compliance with this principle.

20. Ability to supervise on a consolidated basis.

II

The 2001 IMF FSSA finds that the FIN-FSA lacks explicit authority under law to define or limit the range of activities that a consolidated banking group may undertake, or the locations abroad where they may undertake them. However, there is insufficient information publicly available as to Finland's compliance with this principle.

21. Consistent accounting policies and practices that provide a true and fair view of the financial condition of the bank.

II

The 2001 IMF FSSA finds inadequacies in the powers of the FIN-FSA to hold the management of supervised entities responsible for timely, accurate, and reliable financial record keeping and data emissions, as well as for external verification and audit on the annual management reports and financial statements released to the public. Further, the FIN-FSA does not have the power to revoke the appointment of the auditor of a credit institution. The FIN-FSA has only one supervisory power in this matter, to impose conditional fees on the credit institutions. However, there is insufficient information publicly available as to Finland's compliance with this principle.

The FIN-FSA website states that the FIN-FSA was assigned the authority to monitor compliance with the International Financial Reporting Standards (IFRSs) in early 2005. Supervision in this area covers publicly traded Finnish companies and those companies that have applied to issue shares for public trading. Beginning 2007, supervision will also extend to bond-issuing companies. Supervision targets the periodic financial reports published by the issuing companies.

22. Adequate supervisory measures to ensure timely corrective action.

II

The 2007 Global Survey report by the IIB notes that the FIN-FSA has a host of remedial actions that it can take against non-compliant institutions and institutions that do not meet capital adequacy requirements. They include convening and attending the decision-making body meetings of such institutions; placing restrictions on the distribution of profits; inspecting and obtaining information; prohibiting a planned measure or decision; and issuing a public reprimand or warning. The 2007 FIN-FSA report also states that the FIN-FSA has the right to impose sanctions on entities that breach the laws or its regulations. These include public reprimand or warning, administrative fines and penalties, and prohibition on holding positions on the Board or the management. The 2001 IMF FSSA had recommended enhancing the FIN-FSA's powers to take early intervention actions on troubled institutions and defining them in law. Despite the above information, there is little information publicly available addressing Finland's actual compliance with this principle.

23. Banking supervisors must practice global consolidated supervision over their internationally-active banking organizations.

II

The 2001 IMF FSSA notes that the FIN-FSA does not have the power to impose limitations on the activities or require closure of an entity that is not adequately supervised by the host country relative to the risk posed by the subsidiary, or if the host country's regulatory framework prevents effective supervision on a consolidated basis. However, there is insufficient information publicly available as to Finland's compliance with this principle.

24. International exchange of information with other supervisors.

II

The FIN-FSA website declares that the FIN-FSA has extensive cooperation arrangements with the supervisory authorities of other countries, especially the Nordic and other EU countries, on the basis of specific supervisory MoUs. The 2006 BoF annual report (published in 2007) states that the BoF signed a MoU with the Swedish central bank in January 2006 to coordinate financial sector oversight. Additionally, the BoF collaborated with the Nordic-Baltic countries on matters of financial market integration and infrastructure. However, there is insufficient information publicly available as to Finland's compliance with this principle.

25. Supervision of local operation of foreign banks and information sharing with home country supervisors.

II

The 2007 IMF Article IV Consultation report notes that the growth in foreign ownership in the banking sector necessitates greater cooperation between home and host supervisors, especially to prepare for crisis situations. The report finds that the EU legislative framework does not give much role to host supervisors, and does so only on the will of the home supervisor. The 2007 IMF report recommends creation of a framework which allows a more active supervisory role to host supervisors in the interest of financial stability and consumer confidence. The FIN-FSA website adds that the FIN-FSA cooperates closely with its Nordic counterparts in supervising financial conglomerates on the basis of supervisory MoUs as well as specific supervision groups established for the purpose. The 2001 IMF FSSA finds that foreign banks outside of the European Economic Area (EEA) opening branches or subsidiaries in Finland are not required by law to obtain consent or "no objection" statements from their home country supervisors; however, the Finnish MoF must ascertain if they are subject to sufficient home supervision. The IMF therefore recommends that the FIN-FSA require approval or "no objection" statements from the home supervisor before granting license to institutions. Nonetheless, there is insufficient information publicly available as to Finland's compliance with this principle.