I just had to take a look at how the current Haapa asuntorahasto II Ky (Haapa Real Estate Fund II LP) is doing (and a few other things as well).
First, a little history:
A new partnership agreement was made and signed on September 1, 2025:
Haapa Holding II Oy manages the affairs, and Juha Kivimäki, formerly of FinCap, also serves as a proxy (prokuristi). A company founded with €0 in equity doesn’t exactly inspire confidence.
Signatories:
The current partners and capital contributions can be seen in the trade register extract.
Proxies for Haapa asuntorahasto II Ky:
On behalf of Oma Säästöpankki, the new partnership agreement was signed on September 26, 2025:
In this context, it is also worth mentioning that other arrangements have been made elsewhere, primarily regarding Kotamäki and Sarajärvi:
The former GapCon Oy has been renamed Casyr Oy (ID: 2286193-6)
And Gap Holding Oy and GapInvest Oy have been merged into it:
The information for Casyr Oy also showed that Kotamäki does indeed live in Switzerland nowadays:
And the former shelf company GH Asunnot Oy has been renamed Gapcon Oy:
On the timeline, the date of establishment likely coincides with the first problems that arose from the FIN-FSA (Fiva) side.
In the new Gapcon, power is exercised only by Sarajärvi, with Vesa Mäkelä holding proxy:
Finally, a few words about the audits related to this scenario: A structural independence problem in auditing? The case of SK-Reviisorit, Mikko Sillanpää, and KPMG
An auditing network operates around Oma Säästöpankki (OmaSP), where the same auditors simultaneously oversee the accounting of both the bank’s owners and the bank’s largest debtors, even though the interests of these two clients are conflicting.
SK-Reviisorit Ab is an auditing firm based in Seinäjoki that simultaneously audits two entities critical to OmaSP. The first is the Parkanon Säästöpankkisäätiö (Parkano Savings Bank Foundation), a significant owner of the bank. The auditor-in-charge is Simo Viitaniemi. The second entity is the FinCap network’s >16 companies, which represent the bank’s largest individual credit risk. These include, among others, FinCap Oy, Casyr Oy, Gapcon Oy, Citytontti Oy, Koy Sofianparkki, Haapa Holding I, Haapa Funds, Seinäjoki Stadion, Train Factory companies, and As Oy Lauttasaaren Linnahovi, etc. The auditors-in-charge are Petteri Myllymäki and Toni Koivusaari.
The conflict is structural. From the owner foundation’s perspective, the auditor should critically assess whether the bank’s loan loss provisions are sufficient, as understated provisions threaten the value of the foundation’s ownership. From the perspective of the FinCap companies, the auditor should evaluate whether the financial situation of the companies is presented correctly, but an overly critical assessment would lead to larger loan loss provisions at the bank, which in turn would depress the value of the foundation’s ownership. SK-Reviisorit sits on both sides of this equation.
The situation is deepened by the “Koivusaari bridge.” Toni Koivusaari (b. 1992) sits on the board of SK-Reviisorit Ab while also serving as a deputy auditor for Tilintarkastus Mikko Sillanpää Oy. Mikko Sillanpää, in turn, audits the Kuortane Savings Bank Foundation and the Töysä Savings Bank Foundation: totaling >14% of the bank’s voting power. Through Koivusaari, these two auditing chains are linked: Sillanpää is responsible for the foundations, SK-Reviisorit is responsible for the FinCap network, and Koivusaari is in both organizations. It’s worth noting that Mikko Sillanpää is the spouse of OmaSP’s former communications director, Minna Sillanpää.
The third layer is KPMG, which simultaneously audits both Oma Säästöpankki itself and the South Karelia Savings Bank Foundation (Etelä-Karjalan Säästöpankkisäätiö). Thus, the same auditing firm sees the true state of the loan portfolio from within the bank and, on the other hand, evaluates the financial statements of the foundation, where the OmaSP ownership is by far the largest asset.
Overall, the auditing of at least four of OmaSP’s nine owner foundations is directly linked to the auditing of the bank’s borrowers: either through the same firm (SK-Reviisorit, KPMG) or through a personal bridge (Koivusaari). This is not an isolated disqualification situation, but a systemic independence problem.
The accounts of the Lieto Savings Bank Foundation are audited by Ernst & Young, and the 2024 financial statements reveal that Lieto has also participated in the management’s protection commitment.
I look forward with interest to seeing what the earnings release on February 12, 2026, will contain.