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The Lenz & Staehelin memoranda of April 2014, September 2014 and July 2015 highlighted several key aspects of the new Swiss Financial Market Infrastructure Act (“FMIA”) which has been passed by parliament in its finalized form on June 19, 2015. With a view to an expected entering into force of the FMIA on January 1, 2016 the competent bodies have now published drafts of the implementing ordinances to the FMIA.
Following up on the Lenz & Staehelin memorandum of July 2015 that provides an overview of the core obligations regarding the trading of derivatives under the FMIA, i.e. trade reporting, clearing, use of trade platforms and risk mitigation, the purpose of this memorandum is to outline how the implementing ordinances propose to further specify such obligations, their application to the different categories of counterparties and their phase-in.