- The Federal Department of Finance (FDF) will propose to the Federal Council that the Financial Services Act (FinSA) and the Financial Institutions Act (FinIA) – together with the Federal Council’s implementing ordinances – come into force on 1 January 2020.
- Transitional periods of two years are foreseen for the FinSA conduct obligations.
- The threshold for the market entry of foreign financial service providers has been lowered; there is no longer any registration requirement for foreign client advisors (prudentially supervised) of professional or institutional clients.
- A few simplifications in connection with the basic information sheets have been made in FinSO (can be made available to private clients for execution only services even after the transaction has been concluded; basic information sheets may also be in English).
- The requirements for the professional experience and training of qualified managing directors of asset managers and trustees were specified in FinIO.
- The thresholds in FinIO, according to which the independence of risk management and compliance over profit-oriented activities is not required, have been raised; however, regardless of its size, this exception only applies if a business model without increased risks is in place.
Update FinSA/FinIA – September 2019
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