Applying for a financial sector licence. Navigating a supervisory inspection. Preparing for a corporate reorganisation subject to supervisory authority’s approval. In each of these processes, the way you engage with the regulator matters ‒ and the right preparation can save considerable time and uncertainty.
Silvaliisa Virri knows this better than most. She spent years on the other side of the table at the Finnish Financial Supervisory Authority (FIN-FSA). In February, she joined HPP ‒ bringing with her a rare combination of supervisory authority experience and legal expertise that few advisors can offer.
With Silvaliisa on board, HPP can offer clients deeper and broader advice on financial regulation, support across a full range of regulatory processes, and greater expertise in corporate governance as well as transactions and restructurings for regulated companies.
We asked Silvaliisa what drew her back to advisory work, and how her background as a regulator shapes HPP’s client work.
Why return to the advisory side?
“The desire to return to the legal side grew on me gradually. While working as a regulator, I often found that the most rewarding moments were discussions with companies ‒ situations where there was no established operating model or ready-made solution and where the challenge was to find an answer that both satisfied the supervisory authority’s requirements and worked in practice for the company. A supervisory authority cannot take on the role of an advisor, but I found myself increasingly drawn to precisely that role: where advice goes beyond what is strictly laid down in law.”
Why choose HPP?
“I realised that HPP didn’t yet have a dedicated expert in financial regulation, and I was genuinely interested in building something new. The strategy and brand renewal underway at HPP sounded inspiring, and the slogan ‘Business Law That Matters’, which captures HPP’s mindset so well, really resonated with me. My first two months have already shown that HPP was the right fit.”
What does this mean for HPP’s clients?
“I know what information the FIN-FSA is paying attention to when it reviews an application or other documentation or holds a meeting with a supervised entity. The knowledge of the authority’s practices, processes and expectations is something I can now bring directly to our clients, whether they are long-established players in the financial sector or new entrants navigating the landscape for the first time.”
What to consider when working with the FIN-FSA
After years at the FIN-FSA, Silvaliisa has a clear view of the most common mistakes companies make when engaging with the authority, and what makes a smooth process. Below, she shares three key points to keep in mind when working with the FIN-FSA.
1. Come with a well-reasoned proposal
There is a significantly higher likelihood that things will go as you wish if the matter has already been considered and the solutions justified before you open discussions with the authority. Do not arrive with an open question when you could arrive with a well-prepared answer.
The authority also monitors the effectiveness of the company’s governance system and the suitability (i.e. fitness) of the management, so in this respect too it is important to demonstrate that the company has assessed the matter thoroughly and that its management genuinely understands the implications of the regulation in question.
2. Do not take the authority by surprise
When planning the timetable for larger projects, such as applying for a licence, or various corporate reorganisations, it is essential to factor in the time required for the regulatory process and to inform the regulator as early as possible.
Plans evolve and timetables change: the authority fully understands this. You can also present your preferred timetable directly to the authority, and they will more often than expected endeavour to accommodate timetable requests communicated at an early stage. What they respond to much less well is being informed of a tight deadline at the last minute – particularly just before a holiday season.
3. Seek to understand the authority’s perspective
Sometimes the authority and the company may appear to be speaking different languages, or their starting points are so far apart that the matter simply does not progress. If it feels as though the supervisor does not understand what you are trying to communicate, or if their message is difficult to interpret or seems to be going off on a tangent, it may be time to seek outside help before the matter becomes further complicated.
It is also worth bearing in mind that the supervisor may have another matter on their mind besides the one at hand. An experienced advisor can often help identify the underlying concern and find the right way to convey your message to the supervisor.
If your company is navigating a regulatory process ‒ whether a licence application, a supervisory inspection, a corporate reorganisation or any other matter involving the FIN-FSA ‒ Silvaliisa and the HPP team are ready to help.
