Swiss Representation

A SIMPLE AND COMPREHENSIVE REPRESENTATION SERVICE FOR ACCESS TO THE SWISS MARKET

As a Swiss representative, we are responsible for the activities of the clients we represent not only towards investors in Switzerland but also towards the Swiss authorities. We act as the point of contact for information between the funds and the investors as well as between the funds and FINMA.

REYL Offering

Swiss Representative & Swiss Paying Agent: regulated and authorised by FINMA
Fund distribution advisory – our team of experts provide advice on:
- Client segmentation
- Fund document review & update: provision of Swiss mandatory wording
- Ombudsman selection & affiliation
- Register of Client Advisors selection & affiliation
FINMA filing and authorisation: we obtain and maintain FINMA approval for foreign collective investment schemes offered for sale to all Swiss-based investors (private, professional, and institutional).
Compliance coverage: we ensure compliance with the representation legal framework for alternative funds offered to qualified (i.e. institutional and professional) investors, including HNW retail clients and their private investment structures (family offices).
One of the leading Swiss Representatives: working with over 1’000 funds and 200 investment managers globally.
Swiss Paying Agent: as a regulated bank, we provide a combined solution that minimises the administrative and due diligence burden for investment managers.

Swiss Regulatory Framework

As of 1 January 2020, the Financial Services Act (“FinSA”) and the Financial Institutions Act (“FinIA”) have come into full effect. These two sets of regulations complement, but do not replace, the existing regulation in place, the Collective Investment Scheme Act (“CISA”). The aim of FinSA and FinIA is to align the Swiss regulatory regime to MiFID II, with the ultimate objective of increasing client protection and transparency.

Amended Collective Investment Scheme Act (CISA):

Define and regulate funds as a product
Define “distribution” as any solicitation for an investment into a fund
In force since 2006
Amended March 2015 expanding requirements for qualified investors
Further amended in January 2020 with the introduction of FinSA and FinIA

Financial Services Act (FinSA):

Oversee financial services and regulate product offering
Set rules for Representative and Paying Agent
Under this, investment managers offering a fund to Swiss-based investors must:
- Classify investors according to defined client segmentation (i.e. private, opted-out, opted-in, professional, institutional)
- Comply with local organisational requirements
- Comply with local conduct rules
- Appoint an ombudsman
- In some instances, affiliate with a Client Advisor Register

Financial Institutions Act (FinIA):

Govern the requirements for acting as a financial institution