November 2020

On November 12, 2020, the Swiss Financial Market Supervisory Authority ("FINMA") has published its Ordinance on Financial Institutions ("FinIO-FINMA"). The new FinIO-FINMA clarifies and regulates the details of professional liability insurance for portfolio managers, trustees and managers of collective assets, provides further details on the calculation of the de minimis threshold for asset managers of collective assets, and on risk management and internal control system for asset managers of collective assets. At the same time, FINMA also published a wide range of amendments to other FINMA ordinances and circulars, most of which seek to conform such ordinances and circulars to the Financial Services Act and the Financial Institutions Act. Among these amended ordinances and circulars, FINMA has published an amended circular on outsourcing, which now also covers asset managers of collective assets and fund management companies.