
The Act on the Municipal Guarantee Board (MGB Act)
sets limits on the operations of MuniFin Group, which
can also be considered as an important credit risk
management tool. The Municipal Guarantee Board
(MGB) is an institution governed by the public law, whose
purpose under the MGB Act is to secure and develop the
joint municipal funding. To accomplish this purpose MGB
can grant guarantees to the funding of credit institutions
controlled or owned directly or indirectly by municipalities
if the funding is used for financing of municipalities,
joint municipal authorities and municipality-controlled
entities, as well as non-profit corporations and other
non-profit entities nominated by the Housing Finance
and Development Centre of Finland (ARA). Financing,
derivatives and other services can be offered only to
customers and objects in accordance with the MGB Act.
All funding issued by MuniFin has a MGB guarantee. In
addition, MuniFin has guarantees granted by MGB to
mitigate the counterparty credit risk of some derivative
counterparties.
In addition to the MGB Act, a material credit risk
management principle is that all customer financing and
the derivatives offered to customers have to obtain the
so-called zero risk weight in MuniFin Group’s capital
adequacy calculation. As a business model, this zero risk
requirement for all customer financing, is different from
other credit institutions’ and the credit risk principles
inherent and required in their credit risk policies. MuniFin
Group’s Credit risk policy and credit risk management
practices rely significantly on this principle.
MuniFin’s customers consist of municipalities, joint
municipal authorities, and municipality-controlled entities,
as well as non-profit corporations and other non-profit
organisations nominated by the Housing Finance and
Development Centre of Finland (ARA). MuniFin Group
may only grant loans and leasing financing without
a separate security directly to a municipality or joint
municipal authority. For others, loans must be secured
with an absolute guarantee issued by a municipality or
joint municipal authority or a real estate collateral and a
state deficiency guarantee. The guarantee or guarantee
together with a real estate collateral has to fully cover
the financing provided. Guarantees and the fair value
of collateral received are also taken into account in the
calculation of expected credit losses. The Group does not
bear the residual value risk for the objects of its leasing
services. MuniFin Group has not had credit losses from the
financing of its customers after the realisation of any real
estate collateral and guarantees have taken place.
Municipal customers are divided into three sectors:
municipalities, joint municipal authorities and municipal
companies. By law, a Finnish municipality cannot default
(Bankruptcy Act 120/2004). The municipalities have an
unlimited right to increase local income tax rates and due
to this, together with other elements of autonomy, the
Finnish municipal sector has, similar to sovereigns, a zero
credit risk weighting in capital adequacy calculation of
credit institutions. Finnish municipalities and cities can also
establish joint municipal authorities to provide services
that they are legally required to provide for their citizens or
undertake regional development activities. Municipalities
are jointly members of these joint municipal authorities
and are commonly responsible for their funding and other
liabilities. All loans to municipal companies are guaranteed
by municipalities (or joint municipal authorities). Thus
there is always a municipality, that cannot default by
law, to carry the risk of default. When a loan has a 100%
absolute guarantee from a municipality or a joint municipal
authority, MuniFin Group can apply for payment directly
from the guarantor in accordance with the terms of the
loan. The guarantor is committed based on the guarantee
commitment to pay the interest and other ancillary costs in
addition to the principal.
The housing customer group consists of two types of
housing institutions: institutions owned or controlled
by municipalities (or joint municipal authorities) and
state-subsidised housing institutions. Loans for housing
companies owned by municipalities or joint municipal au-
thorities are guaranteed by municipalities, or these loans
can also at the same be categorised as state-subsidised
housing loans. In such cases there is real estate collateral
and a deficiency guarantee from the State of Finland.
State-subsidised housing institutions are defined as
corporations designated by state authority and engaged in
the renting or production and maintenance of housing, or
corporations controlled by them. The housing companies
are nominated by the Housing Finance and Development
Centre of Finland (ARA), a governmental agency operating
under the supervision of the Ministry of the Environment.
Loans for housing companies have a deficiency guarantee
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Report of the Board of Directors Consolidated Financial Statements Parent Company Financial Statements
Municipality Finance Plc • Annual Report 2020