Synopsis of the most important regulatory developments - Status: 1 April 2019 www.pwc.ch/regulatorydevelopments
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www.pwc.ch/regulatorydevelopments
Synopsis of the most
important regulatory
developments
Status: 1 April 2019
Banking and Asset Management –
what countsSynopsis of the most important developments
(status as at 1 April 2019)
Interdisciplinary projects
2020
2020
2024
2022
2023
2025
2018
2019
2021
page
May
May
Apr
Mar
Mar
Nov
Nov
Aug
Aug
Jun
Jun
Apr
Jan
Jan
Dec
Dec
Feb
Feb
Sep
Sep
Oct
Oct
Jul
Jul
Auditing
FINMA circ. 13/3 'Auditing' 5
1.
FINMA circular 13/3 ‘Auditing’ (Fintech 5
15.
15.
≈
licence partial revision)
Anti-money laundering/compliance
Federal Act to Increase the Effectiveness of 5
Combating Money Laundering and Terrorist
≈
Financing
Anti-Money Laundering Ordinance (Fintech 6
26.
10.
1.
licence)
Anti-Money Laundering Ordinance (AMLO- 6
1.
FINMA)
Agreement on the Swiss banks' code of 6
conduct with regard to the exercise of due
1.
diligence (CDB 20)
Federal Act to Implement the 7
Recommendations of the Global Forum on
22.
20.
≈
≈
≈
the Transparency of Legal Entities and the
Exchange of Information for Tax Purposes
FINMA circ. 16/7 ‘Video and online 7
1.
identification’
Organisation of financial market
Financial Services Act (FinSA) 8
24 4. 24 4.
≈
Financial Services Ordinance (FinSO) 8
6.
≈
≈
≈
Financial Institutions Act (FinIA) 9
≈
Financial Institutions Ordinance (FinIO) 9
6.
≈
FMIO (extended transitional period for small 9
31.12.
1.1.
1.
non-financial counterparties)
FMIO-FINMA (introduction of a clearing 10
29.
1.
obligation)
FINMA guidance 02/2017 (FMIA: reporting 10
31.
1.
requirements/trade repositories)
Ord. to the Financial Market Supervision Act 10
≈
≈
(FINMASA)
Other topics
Amendment to the Code of Obligations (Law 11
≈
≈
on companies limited by shares)
Amendment of the Code of Obligations 11
(indirect counter-proposal to the ‘Responsible
≈
Business’ initiative)
Amendment of the Gender Equality Act 11
28.
7.
≈
(EqA)(introduction of regular pay analyses)
Federal Act on Data Protection (FADP) (total 12
≈
≈
revision)
FINMA guidance 03/2018 (LIBOR: risks of 12
31.12.
1.1.
17.
≈
potential replacement)
Federal Act on the Adaptation of Federal Law 13
28.
22.
to Developments in Distributed Ledger
Technology
Consideration by Parlia- In force, end of final transition
Development
ment period
Hearing/consultation Publication of final regu-
Full application
lation
Publication of results of hear-
ing/consultation/dispatch
Referendum deadline ≈ Estimated/approximately
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 2Banks/securities dealers
2020
2020
2024
2022
2023
2025
2018
2019
2021
page
May
May
Apr
Mar
Mar
Nov
Nov
Aug
Aug
Jun
Jun
Apr
Jan
Jan
Dec
Dec
Feb
Feb
Sep
Sep
Oct
Oct
Jul
Jul
Accounting
FINMA circ. 15/1 ‘Accounting – banks’ 14
18.
18.
(ARB)(changes to the creation of additional
≈
≈
value adjustments for default risks)
Disclosure
31. 31. 31.
FINMA circ. 08/22 ‘Disclosure’ 14
FINMA circ. 16/1 ‘Disclosure’ (phase I) 15
FINMA circ. 16/1 ‘Disclosure’ (phase II) 15
FINMA circ. 16/1 ‘Disclosure’ (phase III) 15
≈
Capital adequacy/risk diversification
31.
CAO (revision dated 1 June 2012) 16
1.
31. 31.
CAO ('too big to fail) 16
1. 1.
CAO / FINMA circ. 17/7 ‘Credit risks’ 17
FINMA circ. 17/7 ‘Credit risks’ (addition to 17
24.
concordance tables)
FINMA circ. 17/7 ‘Credit risks’ (credit risk 17
1.
management requirements)
FINMA circ. 17/7 ‘Credit risks' (replicate 17
31.
extensions to SA-CCR and MCA transition
1.
periods)
31
FINMA circ. 08/23 'Risk diversification' 18
CAO / FINMA circ. 19/1 ‘Risk diversification’ 18
1.
CAO / FINMA circ. 08/20 ‘Market risks’ 18
≈
≈
≈
≈
(fundamental review of the trading book)
FINMA circ.11/2 'Capital buffer and capital 18
1.
planning – banks'
FINMA circ. 13/1 ‘Eligible equity capital 18
1.
banks'
21.
31.
CAO (gone concern requirements) 19
1.
Basel III framework revision (post-crisis 19
1.1.
reforms)
Liquidity
LiqO/FINMA circ. 15/2 'Liquidity risks' 20
31.
1.
(quantitative requirements)
LiqO/FINMA circ. 15/2 ‘Liquidity risks’ 20
≈
(partial revision of NSFR)
Credit business
SBA minimum requirements for mortgage 20
20.
≈
financing
Organisation/risk management
31.
FINMA circ. 08/6 ‘Interest rate risks’ 20
FINMA circ. 19/2 ‘Interest rate risks’ 20
1.
1.4
FINMA circ. 08/7 ‘Outsourcing' 21
FINMA guidance 01/2018 (implementing the 21
30.
requirement for amending financial
1.
1.
contracts)
Fintech
BankA (reducing the market entry barriers 21
4.
1.
for Fintech companies)
BankO (implementation of less stringent 21
30.
licencing requirements for Fintech
1.
companies)
FINMA circ. 08/3 ‘Public deposits with non- 21
15.
15.
≈
banks’
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 32020
2020
2024
2022
2023
2025
2018
2019
2021
page
May
May
Apr
Mar
Mar
Nov
Nov
Aug
Aug
Jun
Jun
Apr
Jan
Jan
Dec
Dec
Feb
Feb
Sep
Sep
Oct
Oct
Jul
Jul
Regime for small banks
Regime for small banks (pilot phase) 22
≈
CAO (adjustments to the regime for small 22
≈
≈
≈
banks)
FINMA circ. 08/21 ‘Operational risks’ 22
≈
≈
≈
(adjustments to the regime for small banks)
FINMA circ. 11/2 ‘Capital buffer and capital 22
planning’ (adjustments to the regime for
≈
≈
≈
small banks)
FINMA circ. 15/2 ‘Liquidity risks’ 22
≈
≈
≈
(adjustments to the regime for small banks)
FINMA circ. 15/3 ‘Leverage ratio’ 23
≈
≈
≈
(adjustments to the regime for small banks)
FINMA circ. 16/1 ‘Disclosure’ (adjustments to 23
≈
≈
≈
the regime for small banks)
FINMA circ. 17/1 ‘Corporate governance’ 23
≈
≈
≈
(adjustments to the regime for small banks)
FINMA circ. 18/3 ‘Outsourcing’ (adjustments 23
≈
≈
≈
to the regime for small banks)
Other topics
14.
BankA (strengthening depositor protection) 23
8.
BankA (participation capital of a cooperative 24
4.
bank)
Fund management companies/investment funds/
representatives of foreign collective investment schemes 2020
2020
2024
2022
2023
2025
2018
2019
2021
page
May
May
Apr
Mar
Mar
Nov
Nov
Aug
Aug
Jun
Jun
Apr
Jan
Jan
Dec
Dec
Feb
Feb
Sep
Sep
Oct
Oct
Jul
Jul
CISA (introduction of funds not subject to 24
≈
≈
authorisation)
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 4Most important aspects and changes
Interdisciplinary projects
Regulation Most important aspects/changes Status
Auditing
FINMA circular 13/3 • Relaxation of the audit cycles within the basic audit: In force since:
‘Auditing’ − Audit areas with ‘medium’ net risk: audit every 6 1 January 2019
years instead of a 3-year cycle;
− Fewer, more intensive regulatory audits for
banks without observable issues performed no
more than every 3 years (category 5) and every 2
years (category 4), if FINMA approves the Board
of Directors’ proposal.
• Regulatory auditing activities to be more risk-ori-
ented by focussing on higher-risk audit areas.
• Greater reliance on the work performed by Internal
Audit is permitted.
• Greater involvement of the Board of Directors in risk
analysis and the development of the audit strategy,
which can be discussed and/or agreed with the
Board of Directors before submitting the documents
to FINMA.
FINMA circular 13/3 • New provisions issued for the regulatory audit of in- Hearing until
‘Auditing’ stitutions under art. 1b BankA. 15 May 2019
(Fintech licence partial re- • Based on the auditing of banks and securities deal- Expected entry into
vision) ers. force: autumn 2019
• Takes into account the relaxation of the rules for in-
stitutions with a Fintech licence by reducing the au-
dit scope.
Anti-money laundering/compliance
Federal Act to Increase • Stipulates the explicit duty of financial intermediar- Hearing until:
the Effectiveness of ies to check the details of the beneficial owner. 21 September 2018
Combating Money • Duty to perform a regular risk-based review of Expected entry into
Laundering and Terror- whether the client documentation is up to date. force: 1 January 2020
ist Financing (Anti-
Money Laundering Act, • Advisory services (foundation, acquisition, disposal,
AMLA) administration and funding) of
− companies with registered offices abroad,
− domiciliary companies with registered offices in
Switzerland, and
− trusts
are subject to the requirements of the ALMA, and
introduction of the duty of due diligence and audit
requirement for advisors.
• Extension of the duty of due diligence for traders to
cover traders in precious metals and precious stones
for transactions above CHF 15,000.
• Associations that collect or distribute assets abroad
for charitable purposes must be entered in the com-
mercial register.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 5Regulation Most important aspects/changes Status
Anti-Money Laundering • Sets out the duties of due diligence for future In force since:
Ordinance (AMLO- Fintech licence holders (entities under art. 1b 1 January 2019
FINMA) BankA).
(Fintech licence) • Based on duties of due diligence for DSFIs, e.g.
− FINMA may demand the implementation of an
IT-based transaction monitoring system;
− No relaxation with regard to setting the criteria
that indicate business relationships involving
higher risks;
− Anti-Money Laundering Office has reduced ac-
tivities if gross income less than CHF 1.5 million
and business model presents limited risks.
Anti-Money Laundering • Extension and specification of the criteria that indi- Entry into force:
Ordinance (AMLO- cate business relationships involving higher risks. 1 January 2020
FINMA) • Specification of the requirements relating to group-
wide compliance with the fundamental principles of
money-laundering prevention and the overall moni-
toring of legal and reputation risks by financial in-
termediaries engaged in activities abroad.
• Threshold for cash transactions with occasional cus-
tomers and the subscription of unlisted collective in-
vestment schemes lowered from CHF 25,000 to
CHF 15,000.
• Duty to check the information about the client and
the beneficiary involved in a payment transaction.
• Due to the disputed legal basis, the duties concern-
ing the regular update of client documentation and
checks of the information on beneficial owners are
no longer part of the AMLO-FINMA.
Agreement on the Swiss • Threshold for cash transactions requiring identifica- Entry into force:
banks’ code of conduct tion of the contracting partner in spot transactions 1 January 2020
with regard to the exer- lowered from CHF 25,000 to CHF 15,000.
cise of due diligence • FINMA circ. ‘Video and online identification’ for-
(CDB 20) mally included in the CDB.
• Deadline to obtain missing information or docu-
ments when opening a new account cut from 90
days to 30 days.
• Update of the provisions regarding the abridged pro-
cedure before the CDB supervisory board.
• Specification and simplification of forms A, I, K, S
and T.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 6Regulation Most important aspects/changes Status
Federal Act to Imple- • Conversion of bearer shares into registered shares Considered by the
ment the Recommenda- for non-listed companies and companies that do not National Council on
tions of the Global Fo- issue shares as intermediated securities. 20 March 2019
rum on the Transpar- • Introduction of a system of sanctions for breaches of
ency of Legal Entities the following duties: Expected entry into
and the Exchange of In-
− Reporting by the shareholders of the beneficial force:
formation for Tax Pur-
owners; and 1 October 2019
poses
− Keeping registers of shareholders and beneficial
owners. Expected transitional
• Right of inspection of authorities and financial inter- period for conversion
mediaries. to registered shares: 18
months after entry into
• Amendments to various laws: Code of Obligations, force
Criminal Code, Tax Administrative Assistance Act
and Intermediated Securities Act.
FINMA circular 16/7 • Amendment of the circular to take into considera- In force since:
‘Video and online iden- tion rapid technological change. 1 August 2018
tification’ • Video identification: Transitional period un-
til 1 January 2020
− Verification using a one-time transaction num-
ber (TAN) is no longer required;
− At least two security features contained in the
identification documentation should now be ver-
ified.
• Online identification:
− Customer due diligence no longer requires pay-
ment transfer from a Switzerland-based bank.
Under specific rules, a payment transfer from a
bank based in a Financial Action Task Force
(FATF) member country will now suffice.
• Using liveness detection to check photos.
• Identification documents are compared with refer-
ence data if the financial intermediary is not familiar
with the documents submitted.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 7Regulation Most important aspects/changes Status
Organisation of financial market
Financial Services Act • Adjustment of the code of conduct and product rules Adopted by Parliament
(FinSA) in the customer segment concerned (private custom- on 15 June 2018
ers/professional customers): Referendum deadline:
− Information on financial services provider, ser- 4 October 2018
vice and product, including by means of a key in- Expected entry into
formation document; force:
− Suitability check before transactions involving fi- 1 January 2020
nancial instruments (except ‘execution-only’); Transition periods up
− Suitability check if providing advice and asset to 2 years after entry
management services. into force
• Guidelines regarding the organisation of financial
services providers and the avoidance of conflicts of
interest.
• Duty to inform about accepting compensation from
third parties or obligation to pass on compensation
from third parties.
• Obligation to enter client advisers in the register of
client advisers if financial service providers are not
supervised in accordance with FINMASA, and to en-
gage in continuing professional education and train-
ing.
• Extension of legal means in favour of customers, in-
cluding right to the publication of documents.
• Transitional periods after entry into force:
− 6 months for the registration of client advisers
and affiliation of financial services providers
with an ombudsman;
− 2 years for the introduction of the duties relating
to the provision of financial services (e.g. duty to
publish a prospectus for securities, key infor-
mation document for financial instruments, pub-
lication).
Financial Services Ordi- • Specification of financial service providers’ duties to Hearing until:
nance (FinSO) provide advice and information. 6 February 2019
• Implementing regulations for the provisions of the Expected entry into
FinSA: force:
1 January 2020
− Organisation of financial services providers;
Transitional period un-
− New register of client advisers; til 1 January 2021 to
− Client documentation; comply with the duties
− Ombudsman services; regarding client seg-
mentation, expertise,
− Prospectus when offering securities; code of conduct, organ-
− Key information document. isation
Various other transi-
tional periods for the
publication of prospec-
tuses and key infor-
mation documents
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 8Regulation Most important aspects/changes Status
Financial Institutions • Regulation of the licensing obligation and the super- Adopted by Parliament
Act (FinIA) vision of all financial service providers that operate on 15 June 2018
an asset management business, i.e. asset managers, Referendum deadline:
trustees, fund administrators, fund managers and 4 October 2018
securities houses.
Expected entry into
• Banks, insurance companies and pension funds, force:
among others, are not subject to the Financial Insti- 1 January 2020
tutions Act. Transition periods up
• Definition of the licensing requirements with regula- to 3 years after entry
tions concerning the organisation, assurance of into force
proper conduct of business, legal form, risk manage-
ment, internal controls and capital requirements.
• Transitional periods:
− Financial institution newly subject to licensing
obligation: Notify FINMA within 6 months of
entry into force, with the obligation to satisfy the
requirements of this act and submit a licence ap-
plication within three years of the act’s entry into
force;
− Asset managers and trustees: Notify FINMA
immediately if business activities are started
within 1 year of FinIA entering into force, with
the obligation to affiliate and submit a licence
application to the supervisory body within 1 year
of approval by the supervisory body.
Financial Institutions • Specification of the implementing provisions relat- Hearing until 6 Febru-
Ordinance (FinIO) ing to the Financial Institutions Act (FinIA). ary 2019
• Regulations relating to authorisation and organisa- Expected entry into
tional requirements for supervised financial institu- force:
tions. 1 January 2020
Financial Market In- • Extension of transitional period to 1 January 2024 In force since:
frastructure Ordinance for small non-financial counterparties to report de- 1 January 2019
(FMIO) rivatives transactions. Transitional period un-
(extended transitional pe- • No change in transitional deadlines for financial til 1 January 2024
riod for small non-financial counterparties and for non-financial counterparties
counterparties) which are not small.
• Review of FMIO to be initiated as of 2019 in light of
international and technological developments.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 9Regulation Most important aspects/changes Status
FINMA Financial Mar- • New clearing obligation will apply to standardised Entry into force: 1 Sep-
ket Infrastructure Ordi- interest rate and credit derivatives traded over the tember 2018
nance (FMIO-FINMA) counter (OTC). Transitional periods
(introduction of a clearing • Obligation applies to financial and non-financial from 6 to 18 months af-
obligation) counterparties whose positions in OTC derivatives ter the entry into force
transactions exceed the clearing thresholds set out in
art. 88 FMIO (credit/equity derivatives: CHF 1.1 bil-
lion; interest rate/currency/commodity and other
derivatives).
• Transitional periods ranging from 6 to 18 months af-
ter the entry into force of Annex 1 of the FMIO-
FINMA depending on the classification in accord-
ance with art. 85 FMIO until the clearing obligation
is mandatory.
• FINMA is considering an exception, to be an-
nounced in a FINMA Guidance, if it emerges by 1
February 2019 that certain CCPs will not be recog-
nised before the entry into force of the clearing obli-
gation.
FINMA guidance • The authorisation of a Swiss trade repository (SIX Reporting obligation
02/2017 and 05/2017 Trade Repository AG) and the recognition of a for- must be fulfilled by 1
FMIA: reporting require- eign trade repository (Regis-TR S.A.) trigger the re- January 2019, at the
ments/trade repositories quirement for Swiss market participants to report latest, depending on
derivatives transactions. the type and size of the
• Open derivatives transactions must be reported persons subject to the
from the following dates at the latest: reporting requirement
− From 1 October 2017, if the counterparty which
is required to report is a central counterparty
(CCP) or a financial counterparty (FC) which is
not small;
− From 1 January 2018, if the counterparty which
is required to report is a small financial counter-
party (FC-) or a non-financial counterparty
(NFC) which is not small;
− From 1 January 2019, in all other cases; how-
ever, transactions between two small non-finan-
cial counterparties (NFC-) do not have to be re-
ported.
Ordinance to the Finan- • Specification of the role and competences of the fi- Hearing expected in
cial Market Supervision nancial market authorities with regard to regulation April 2019
Act (FINMASA) and international standard setting.
• Regulation of the cooperation between the FDF and
FINMA.
• Specification of the regulation principles and pro-
cess according to art. 7 FINMASA.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 10Regulation Most important aspects/changes Status
Other topics
Amendment of the • Implementation of the provisions of the Ordinance Federal Dispatch to
Code of Obligations against excessive remuneration in listed companies Parliament published
(law on companies limited limited by shares (ERCO) in federal law. on 23 November 2016
by shares) • Establishes guidelines for signing-on bonuses and Considered by the Na-
compensation for prohibition of competition. tional Council on
14 June 2018 and by
• Liberalisation of the incorporation and capital provi-
the Council of States on
sions.
11 December 2018
• Better alignment of the law on companies limited by
Expected entry into
shares (Company Law) to the new Accounting Law, force: beginning of
e.g. regarding a company’s own shares and the use 2021, at the earliest
of foreign currencies in accounting and financial re-
porting.
• Gender quotas for the Board of Directors (min. 30%
each) and Executive Board (min. 20%) of large listed
companies – ‘comply or explain’ clause.
• Proposed solutions with regard to shares held that
are not recorded in the stock register (so-called
‘dispo shares’).
• Increased transparency requirements applicable to
the commodities sector through the disclosure of
payments to state-owned entities.
Amendment of the • Duty to comply with regulations for the protection of Considered by the Na-
Code of Obligations human rights and the environment, including tional Council on
(indirect counter-proposal abroad, for companies that exceed two of the follow- 14 June 2018 and by
to the ‘Responsible Busi- ing thresholds: the Council of States on
ness Initiative’) − Total assets: CHF 40 million; 12 March 2019
− Turnover: CHF 80 million;
− 500 full-time employees on average per year.
• Potential extension to cover business relationships
with third parties.
• Obligation to publish an accountability report.
Amendment of the Gen- • Employers must conduct a pay analysis every 4 years Adopted by Parliament
der Equality Act (EqA) if they have more than 100 employees. on 14 December 2018
(introduction of regular pay • Employer is exempted if the analysis shows pay is Referendum deadline:
analyses) equal. 7 April 2019
• Pay analyses performed using a standard analysis Expected entry into
tool provided by the Federal Government or using a force 1 January 2020
scientific and legally compliant method.
• Review of internal pay analysis by an independent
body:
− Authorised audit firm; or
− Organisations for the representation of employ-
ees or the promotion of gender equality.
• Duty to provide information about the results of
the equal pay analysis
− to the shareholders of listed companies in the
notes to the financial statements; and
− to the employees.
• Measures limited to a period of 12 years.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 11Regulation Most important aspects/changes Status
Federal Act on Data • Extended duties to provide information and keep Considered by the Na-
Protection (FADP) records. tional Council for the
(total revision) • Strengthening of the supervisory body and tighter last time on 17 Septem-
sanctions. ber 2018 and by the
Council of States on
• Takes into consideration the EU’s General Data Pro- 11 September 2018
tection Regulation (EU-GDPR), which applies as of
25 May 2018, and the Council of Europe’s Conven-
tion for the Protection of Individuals with regard to
Automatic Processing of Personal Data (ETS 108).
• Companies that have cross-border business in the
EU must observe the provisions of EU-GDPR.
• In September 2018, Parliament approved a phased
approach to the bill:
− 1. Implementation of EU Directive 2016/680 on
the protection of natural persons with regard to
the processing of personal data by competent au-
thorities for the purposes of the prevention, in-
vestigation, detection or prosecution of criminal
offences or the execution of criminal penalties
(further development of the Schengen acquis);
− 2. Total revision of the Federal Act on Data Pro-
tection (FADP) by approx. end of 2019.
FINMA guidance • Banks currently participating in fixing the LIBOR Replacement of LIBOR
03/2018 will be no longer compelled to contribute rates by the end of 2021 at
(LIBOR: risks of potential from 2021 onwards. the latest
replacement) • The National Working Group on Swiss Franc Ref-
erence Rates (NWG) is developing reform pro-
posals to replace LIBOR.
• Established a basis for replacing the CHF LIBOR
with the introduction of the Swiss Average Rate
Overnight (SARON).
• Risks for the institutions:
− Legal risks relating to contracts for financial
products that have a final maturity date after
2021;
− Valuation risks relating to derivatives and lend-
ing contracts that reference LIBOR;
− Operational readiness.
• FINMA recommends that the supervised institu-
tions address the challenges of a potential replace-
ment of LIBOR in good time.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 12Regulation Most important aspects/changes Status
Federal Act on the Ad- Legal framework for the amendments to several laws in Consultation until
aptation of Federal Law connection with blockchain/distributed ledger technol- 28 June 2019
to Developments in Dis- ogy (DLT):
tributed Ledger Tech- • In the Code of Obligations: Increase legal certainty
nology for the transfer of DLT-based assets by creating the
possibility of digital registers of rights, which can
guarantee the functions of securities.
• In the Federal Act on Debt Collection and Bank-
ruptcy: Increase legal certainty by explicitly regulat-
ing the segregation of crypto-based assets in the
event of bankruptcy.
• In the Financial Market Infrastructure Act: Create a
new authorisation category for DLT-based trading
systems.
• In the Financial Institutions Act: Create the possibil-
ity of authorisation as a securities house for the op-
eration of a trading system.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 13Banks/securities dealers
Regulation Most important aspects/changes Status
Accounting and re-
porting
FINMA ordinance on • New FINMA ordinance on accounting issued with Hearing until
accounting and total re- basic provisions on measurement and recognition. 18 June 2019
vision of FINMA circ. • Integration of accounting and disclosure practice Expected entry into
‘Accounting – banks’ and current FAQs in the total revision of FINMA force: 1 January 2020
circ. 20/xx. Transitional period for
• Introducing an approach for the creation of addi- creation of value adjust-
tional value adjustments alongside the individual ments for expected
value adjustments for doubtful receivables: losses and for inherent
default risks until
− Category 1 banks: 31 December 2026 at
◦ Expected loss approach in accordance with the latest
the international accounting standard used.
− Category 2 banks:
◦ Model-based expected loss approach for all
portfolios using the IRB approach;
◦ Simplified approach for expected losses (e.g.
loss rate approach based on expert opinion)
for items with minimum capital require-
ments according to the standardised ap-
proach.
− Category 3 banks with significant activities in
the interest rate spreads business:
◦ Creation of value adjustments for inherent
default risks within a wide margin;
◦ Use of the value adjustments for inherent
default risks in crisis situations.
− Other banks:
◦ Option to continue the use of the current ap-
proach to value adjustments for latent de-
fault risks on the basis of the incurred loss
approach; or
• Voluntary use of a more comprehensive approach
permitted by all banks.
Disclosure
FINMA circular 08/22 • Acceptance of requirements concerning qualitative In force since:
‘Disclosure – banks’ and quantitative disclosure of: 1 January 2015
(FINMA circular dated 20 − Leverage ratio; Progressively replaced
November 2008, with by FINMA circ. 16/1
− Liquidity coverage ratio (LCR).
amendments of 29 October
2014) • From 2015: disclosure of capital adequacy accord-
ing to the previously applied periodicities:
− For banks with annual disclosure: until end of
April 2016 at the latest (based on year-end 2015
figures);
− For banks with semi-annual disclosure: until
end of August 2015 (based on figures as of end
of June 2015).
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 14Regulation Most important aspects/changes Status
FINMA circular 16/1 • Total revision and replacement of former FINMA In force since:
‘Disclosure – banks’ circ. 08/22 ‘Disclosure – banks’, with focus on 1 January 2016
(phase I – FINMA circ. standardising certain tables in order to improve Transitional period un-
dated 28 October 2015) comparability. til 2019
• Exemption from detailed disclosure requirements For disclosures as of
according to the Basel standards for smaller institu- 31 December 2018,
tions (FINMA supervisory categories 4 and 5). replaced by amend-
• Significant, one-off conversion costs expected for ments to FINMA
about 30 institutions in supervisory categories 1 to circ. 16/1 ‘Disclosure –
3. banks’ (Phase II) of
20 June 2018
• First annual disclosure for banks in:
− Regulatory category 1, by end of April 2017 lat-
est for the financial year ending 31 December
2016;
− Regulatory categories 2 & 3, by end of April
2018 latest;
− Regulatory categories 4 & 5, by end of April
2019 latest.
• Banks that apply the ‘consolidation discount’ and
foreign-owned banks are exempted from the de-
tailed disclosure obligations: publication of at least
6 key figures in the management report, for the first
time as of 31 December 2015.
FINMA circular 16/1 • Option to abstain from disclosing information if not Applicable for
‘Disclosure – banks’ material or meaningful. disclosures as of
(phase II – amendments • Partial revision of the circular aiming to enhance 31 December 2018
dated 20 June 2018) comparability by standardising requirements re- Option to abstain from
garding the content of disclosures. The key amend- disclosing information
ments are: on interest rate risks as
at 31 December 2018, if
− Summary table of key regulatory indicators (key
an extraordinary disclo-
metrics);
sure as at 30 June 2019
− Tables on revised standards of interest rate and is made
market risks;
− Tables for global systemically important banks
with regard to TLAC requirements;
− Tables on remuneration and prudential value
adjustments;
− No requirement to explain why information is
not published if it is unimportant.
FINMA circular 16/1 • Extension of the duties of disclosure in the areas of: Basel Committee stand-
‘Disclosure – banks’ − Credit valuation adjustment (CVA); ard published on
(phase III) 11 December 2018.
− Regulatory treatment of problematic activities;
Implementation in
− Qualitative and quantitative information on op- Swiss law pending, ex-
erational risks; pected entry into force
− Comparison of risk-weighted assets calculated approx. 2020 and 2022
using model-based and standardised ap-
proaches;
− Encumbered/ceded assets;
− Dividend restrictions.
• Adaptation of the other current disclosure tem-
plates and tables from Phase II.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 15Regulation Most important aspects/changes Status
Capital adequacy/risk diversification
Ordinance on Capital • Comprehensive revision of capital adequacy, risk In force since:
Adequacy and Risk Di- diversification and liquidity rules due to changes to 1 January 2013
versification for Banks the Basel III rules. Extensive transitional
and Securities Traders • More stringent requirements concerning the quality period from 2013 until
(CAO) and amount of equity. 2018
(total revision of 1 June
• ‘Swiss Finish’ discontinued (Swiss standard ap-
2012)
proaches to credit risk measurement and risk diver-
sification), with a transitional period running until
31 December 2018 at the latest.
Capital Adequacy Ordi- • Newly calibrated overall requirements for going- In force since:
nance (CAO) concern capital of systemically important banks: 1 July 2016
(amendment of ‘too big to − Basic requirement: 4.5% leverage ratio + Various transitional pe-
fail’ provisions) 12.86% of risk-weighted assets; riods until 2019 latest
− Progressive component depending on market
share;
− Progressive component depending on total
commitment.
• Extension of counter-cyclical buffer for large banks
with significant accounts receivable in the foreign
private non-banking sector:
− Capital buffers calculated as the weighted aver-
age of the buffers in effect in the member states
of the Basel Committee to which banks have sig-
nificant credit exposure;
− The extended counter-cyclical capital buffer is
limited to 2.5% of the weighted exposure.
• Transfer from FINMA circ. 11/2 ‘Capital buffer and
capital planning banks’:
− Capital ratios and capital buffer to the Capital
Adequacy Ordinance (CAO); and
− Categorisation of banks to the Banking Ordi-
nance (BankO).
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 16Regulation Most important aspects/changes Status
Ordinance on Capital • Adaptation of the calculation of derivatives credit Revisions to the Ordi-
Adequacy and Risk Di- equivalent amounts. nance published on
versification for Banks − Introduction of a standard approach to calculate 23 November 2016
and Securities Traders the derivatives credit equivalent amount (coun- Revisions to FINMA cir-
(CAO) terparty credit risk) (SA-CCR); cular published on
FINMA circular 17/7 19 December 2016
− Simplified SA-CCR for institutions in categories
‘Credit risks – banks’ 4 and 5; In force since:
(total revision of FINMA 1 January 2017 with
− Simplified SA-CCR for category 3 institutions
circular 08/19) transition period until
under certain conditions. 1 January 2020 (ex-
• Adaptation of methodology and risk-weighting tended with the publica-
rates for the coverage of unit shares in collective in- tion of the revised CAO
vestment schemes. dated 22 November
− Introduction of various approaches to calculate 2017)
the capital adequacy requirements: Look-
through approach (LTA), mandate-based ap-
proach (MBA) or fallback approach (FBA);
− Institutions in supervisory categories 4 and 5
are allowed to apply the fallback approach
(FBA) with a risk weighting of 250% instead of
1,250%, if the fund has a synthetic risk indicator
of 1 to 4;
− Fallback approach permitted for category 3 in-
stitutions under certain conditions.
• Revision of regulatory capital for securitisation po-
sitions on the banking book.
FINMA circular 17/7 • Addition to the list of recognised rating agencies In force since:
‘Credit risks – banks’ and classes in Appendix 3 with ratings from the 24 December 2018
‘Scope Ratings’ agency.
(addition to concordance
tables)
FINMA circular 17/7 • Definition of the eligibility of spouses’ life insurance In force since:
‘Credit risks – banks’ policies. 1 January 2019
(eligibility of life insurance • Extension of simplified risk-weighting approach of
policies/shares in MCA) unit shares in managed collective assets (MCA) for
instruments with a risk indicator >4.
FINMA circular 17/7 • Circular adopts the transition periods stemming In force since:
‘Credit risks – banks’ from the revision of the Capital Adequacy Ordi- 30 June 2018
nance dated 22 November 2017:
(adoption of extensions to
SA-CCR and MCA transi- − Extension of transition period for applying SA-
tion periods) CCR in the place of the current exposure
method from 1 January 2018 to 1 January 2020.
− Extension of transition period for applying the
new capital adequacy rules for shares in man-
aged collective assets (MCA) held in the banking
book from 1 January 2018 to 1 January 2020.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 17Regulation Most important aspects/changes Status
Ordinance on Capital • Use of freely available capital to cover exposures In force since:
Adequacy and Risk Di- higher than the 25% limit is discontinued, except 1 January 2019
versification for Banks for the processing of client payments for a maxi-
and Securities Traders mum period of 5 bank working days and corporate
(CAO) affiliations.
FINMA circular 19/1 • Exceptions to the 25% upper threshold limited
‘Risk diversification – mainly to positions with central banks and central
banks’ governments and central counterparties.
(amendments to risk diver- • Receivables due from mortgage bond institutions
sification rules) given weighting of 10%.
• Modification of reporting method.
• Obligation to report by end of March 2018 large ex-
posures likely to exceed the 25% upper threshold
when the new rules enter into force.
• Extension of transition period for the introduction
of SA-CCR and the weighting of shares in managed
collective assets from 12 to 36 months.
• New circular replaces FINMA circ. 08/23 ‘Risk di-
versification – banks’.
• Relaxation of the rules for category 4 and 5 banks.
Ordinance on Capital • Implementation of the results of the fundamental Hearing expected:
Adequacy and Risk Di- review of the trading book (FRTB) for the market Q1 2019
versification for Banks risk conditions of the Basel Committee on Banking Expected enactment of
and Securities Traders Supervision (BCBS). the regulations:
(CAO) • Implementation requires further revision of the December 2019
FINMA circular 08/20 Capital Adequacy Ordinance (CAO) and FINMA cir- Expected entry into
‘Market risks – banks’ cular ‘Market risks – banks’. force:
(changes from fundamental • Due to the delay in implementation in other juris- 1 January 2022
review of the trading book) dictions, especially the European Union, the law
will enter into force in Switzerland as of 31 Decem-
ber 2020, at the earliest.
• Further delay expected until 2022 due to the post-
ponement of implementation by the Basel Commit-
tee.
FINMA circular 11/2 • Removed provisions on bank categories and capital In force since:
‘Capital buffer and capi- buffers due to new provisions of the CAO. 1 January 2019
tal planning – banks’ • Definition of the calculation of the target capital
amount (=total capital ratio + countercyclical buffer
+ institution-specific capital buffer).
• Established percentage shortfall of equity capital as
threshold for measures to be taken.
FINMA circular 13/1 ‘El- • Implementation of rules valid from 2019 relating to In force since:
igible equity capital – the treatment of TLAC instruments for capital ade- 1 January 2019
banks’ quacy purposes.
(partial revision) • Specification of current practice for the recognition
of value adjustments for latent default risks:
− Recognised in Tier 2 capital; or
− Deducted from related balance-sheet item or
off-balance-sheet item.
• Revision of the regulatory filter due to the change in
IFRS.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 18Regulation Most important aspects/changes Status
Ordinance on Capital • Introduction of gone-concern minimum capital for In force since:
Adequacy and Risk Di- domestic systemically important banks (D-SIBs). 1 January 2019
versification for Banks • Investments in group companies active in financial Transitional periods for
and Securities Traders services: deduction of financial interests from capi- additional gone-concern
(CAO) tal (in an individual company perspective) replaced minimum capital re-
(gone-concern capital, de- by a financial interest risk-weighting for group com- quirements until 2025
duction of financial inter- panies based in:
ests in subsidiaries and
− Switzerland: 250%
other amendments)
− Abroad: 400%
• Group companies that provide the services neces-
sary for the continuation of a bank’s business pro-
cesses are subject to consolidated supervision by
FINMA.
Basel III framework re- • Revisions to the standardised approach for Implementation of most
vision (post-crisis re- weighting credit risks through: of the Basel Commit-
forms) − Greater differentiation of risk weights rather tee’s reforms by 1 Janu-
than using flat rates, especially for exposures se- ary 2022
cured by residential or commercial property de- Phased increase of out-
pending on the loan-to-value ratio; and put floors for internal
model-based ap-
− Further assessment requirements for the appli-
proaches from 2022 to
cation of external ratings.
2027
• Use of the advanced IRB approach not allowed for
certain exposure classes, especially exposures to
corporates and to financial institutions.
• Revisions to the calculation methodology of credit
valuation adjustments (CVAs).
• Replacement of previous approach to minimum
capital requirements for operational risk (basic in-
dicator, standardised and advanced measurement
approaches) by a standardised approach based on
earnings and historical losses.
• Revision of the calculation methodology of the lev-
erage ratio and introduction of a leverage ratio
buffer for global systemically important banks (G-
SIBs).
• Output floor set for the internal model-based ap-
proaches at a minimum of 72.5% of risk-weighted
assets calculated using the standardised ap-
proaches.
• Entry into force of the requirements for calculating
minimum capital requirements for market risks
(FRTB) postponed from 2019 to 1 January 2022.
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 19Regulation Most important aspects/changes Status
Liquidity
Liquidity Ordinance • Total liquidity regulations replaced by obligation to In force since:
(LiqO) comply with a liquidity coverage ratio (LCR) as of 1 1 January 2015
(changes to the quantitative January 2015, with a basic obligation to report Various transitional pe-
requirements) within 20 working days every month. riods up to 1 January
− From 1 January 2015, non-systemically im- 2019 at the latest
FINMA circular 15/2
‘Liquidity – banks’ portant banks’ compliance set at 60%, with
gradual increase in the percentage up to full
(qualitative requirements compliance as of 1 January 2019.
for liquidity risk manage-
ment and quantitative re- • Introduction of Net Stable Funding Ratio (NSFR) as
quirements for liquidity well as further observation ratios:
maintenance of 3 July − Test reporting in 2015;
2014) − Mandatory reporting as of Q2 2016 to end 2017.
Liquidity Ordinance • Enactment of mandatory requirements relating to Hearing until
(LiqO) the Net Stable Funding Ratio (NSFR). 10 April 2017
FINMA circular 15/2 • Postponement of decision on introduction of NSFR Reassessment of further
‘Liquidity – banks’ in Switzerland until end of 2019 due to significant action:
(partial revision of NSFR) international delays. end of 2019
Credit business
SBA minimum require- • Testing potential measures to shorten the amortisa- Development of deci-
ments for mortgage fi- tion period and reduce the loan-to-value ratio for sion criteria.
nancing residential investment properties.
Organisation/risk management
FINMA circular 08/6 • Repeal of the circular and replacement by the new Repealed as of
‘Interest rate risks – FINMA circ. 19/2 ‘Interest rate risks – banks’. 31 December 2018
banks’
FINMA circular 19/2 • Measurement of interest rate risks using internal In force since:
‘Interest rate risks – interest rate stress and shock scenarios as well as 1 January 2019
banks’ standard interest rate shock scenarios required by
(total revision) supervisory law.
• Scenarios may be relaxed under certain conditions
for medium-sized banks in category 3 with limited
interest operations and for small banks in catego-
ries 4 and 5.
• Specifications concerning the duties of the govern-
ing body, internal reporting, risk appetite, data in-
tegrity and validation as well as internal risk capac-
ity.
• Disclosure of information on interest rate risk.
• Threshold to identify institutions with threatening
interest rate risks (15% of Tier 1 capital).
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 20Regulation Most important aspects/changes Status
FINMA circular 18/3 • Replaces FINMA circular 08/7 ‘Outsourcing – In force since:
‘Outsourcing – banks banks’. 1 April 2018
and insurers’ • Obligation to maintain a record of all outsourced After entry into force:
(total revision) services. immediate application
to new or modified out-
• Requirements of the circular apply to intra-group
sourcing arrangements
outsourcing. However, rules may be relaxed if risks
are proven not to exist or requirements are not rele- Transition period of five
vant. years to amend pre-ex-
isting outsourcing ar-
• In case of outsourcing abroad, all the necessary data rangements
required in the event of restructuring, resolution
and liquidation must be accessible in Switzerland at
all times.
• Extension of the area of application to include in-
surance companies.
FINMA • Transitional periods extended for concluding new Deviations tolerated un-
Guidance 01/2018 financial contracts or amending existing contracts til 31 December 2018
(implementation of the re- governed by foreign law or a foreign jurisdiction in and 30 June 2019, re-
quirement to amend finan- accordance with art. 12 para. 2bis BankO (require- spectively
cial contracts) ment to recognise the deferment or termination of
contracts by FINMA in accordance with art. 30a
BankA).
• In certain circumstances, for up to a maximum pe-
riod of 9 months after the expiry of the correspond-
ing implementation deadline, FINMA will accept if
banks forego declaring a trade stop in order to
achieve full compliance.
Fintech
Banking Act (BankA) • Authorisation of institutions not active in lending In force since:
(reducing the market entry and investing activities and with non-interest-bear- 1 January 2019
barriers for Fintech compa- ing deposits up to CHF 100 million.
nies) • Relaxation of the licensing and operating conditions
and reduced minimum capital, equity and liquidity
requirements.
Banking Ordinance • Implementation of less stringent licencing of In force since:
(BankO) Fintech companies. 1 January 2019
(implementation of less • Regulation of duty to provide information to clients,
stringent licencing require- organisational requirements and minimum capital.
ments for Fintech compa-
nies)
FINMA circular 08/3 • Interpretation of the previously undefined term ‘in- Hearing until
‘Public deposits with terest rate spreads business’. 15 May 2019
non-banks’ Expected entry into
force: autumn 2019
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 21Regulation Most important aspects/changes Status
Regime for small banks
Regime for small banks • Pilot phase until mid-2019 of FINMA’s significantly Pilot phase runs until
(pilot phase) less complex regulatory regime for category 4 and 5 end-2019
banks:
− Simplified calculation of the minimum capital re-
quirements;
− Simplified calculation of the leverage ratio;
− Reduced disclosure of key metrics;
− NSFR requirements do not apply;
− Simplified capital and liquidity planning.
• Possibility to participate in the regime for small
banks if certain criteria are fulfilled, in particular
above-average capitalisation and high liquidity.
Ordinance on Capital • Definitive criteria enshrined in law and simplifica- Hearing expected in
Adequacy and Risk Di- tion of the regime for small banks (applicable to April 2019
versification for Banks banks in categories 4 and 5 participating in the re- Expected entry into
and Securities Traders gime for small banks): force: 1 January 2020
(CAO) − No requirement to calculate risk-weighted as-
(adjustment of the regime sets;
for small banks)
− No future regulatory adjustments in the context
of Basel III in those areas exempted by the re-
gime for small bank regime.
• Adjustments for all banks in categories 4 and 5:
− Option to continue using the current exposure
method instead of the standardised approach to
determine the derivatives credit equivalent
amount (counterparty credit risk).
FINMA circular 08/21 • Simplification for banks participating in the regime Hearing expected in
‘Operational risks – for small banks: April 2019
banks’ − Obligations relating to the handling of elec- Expected entry into
(adjustment of the regime tronic customer data are limited to basic princi- force: 1 January 2020
for small banks) ples.
• Adjustments for all banks in categories 4 and 5:
− Categorisation of operational risks may be
based on either a qualitative or a quantitative
assessment;
− The term ‘IT risk management framework’ not
applied to dealing with risks arising from tech-
nology infrastructure.
FINMA circular 11/2 • Simplification for banks participating in the regime Hearing expected in
‘Capital buffer and capi- for small banks: April 2019
tal planning – banks’ − Capital planning limited to the simplified lever- Expected entry into
(adjustment of the regime age ratio. force: 1 January 2020
for small banks)
FINMA circular 15/2 • Simplification for banks participating in the regime Hearing expected in
‘Liquidity risks – banks’ for small banks: April 2019
(adjustment of the regime − Fewer and more flexible liquidity planning re- Expected entry into
for small banks) quirements; force: 1 January 2020
− No requirement to calculate the Net Stable
Funding Ratio (NSFR).
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 22Regulation Most important aspects/changes Status
FINMA circular 15/3 • Simplification for banks participating in the regime Hearing expected in
‘Leverage ratio – banks’ for small banks: April 2019
(adjustment of the regime − Simplified calculation of the leverage ratio Expected entry into
for small banks) based on the current term sheets for the regime force: 1 January 2020
for small banks.
FINMA circular 16/1 • Simplification for banks participating in the regime Hearing expected in
‘Disclosure – banks’ for small banks: April 2019
(adjustment of the regime − No requirement for regulatory disclosure, ex- Expected entry into
for small banks) cept for the ‘key metrics’ table. force: 1 January 2020
FINMA circular 17/1 • Simplification for banks participating in the regime Hearing expected in
‘Corporate governance for small banks: April 2019
– banks’ − Exempted from performing stress tests, but sce- Expected entry into
(adjustment of the regime nario analyses must be conducted at least; force: 1 January 2020
for small banks)
− A risk assessment by Internal Audit is no longer
necessary every year, but only every two years.
• Adjustments for all banks in categories 4 and 5:
− More flexible documentation form as the term
‘Framework for enterprise-wide risk manage-
ment’ is no longer applied.
FINMA circular 18/3 • Simplification for banks participating in the regime Hearing expected in
‘Outsourcing – banks for small banks: April 2019
and insurers’ − Risk management with regard to outsourcing is Expected entry into
(adjustment of the regime possible by relying extensively on reporting by force: 1 January 2020
for small banks) an independent auditor.
• Adjustments for all banks in categories 4 and 5:
− Principle of proportionality is mentioned explic-
itly in the circular.
Other topics
Banking Act (BankA) • Measures to improve depositor protection: Hearing until
(insolvency, deposit insur- − Period in which insured deposits are paid out in 14 June 2019
ance, segregation) the event of bankruptcy shortened to 7 working
days;
− Deposit of securities or cash in the amount of
50% of the contribution obligation;
− No requirement to hold liquidity for potential
cash outflows to the depositor protection
scheme;
− The scheme’s systemic upper limit is to be in-
creased to 1.6% of the total amount of insured
deposits and at least CHF 6 billion.
• Introduction of the obligation to segregate proprie-
tary assets and customers’ assets recorded in cus-
tody accounts throughout the entire domestic ‘cus-
tody chain’.
• Improving the function of the Swiss mortgage bond
system in the event of the insolvency of a member
bank by amending the Mortgage Bond Act (MBoA).
PwC Synopsis of the most important regulatory developments (as at 1 April 2019) 23Regulation Most important aspects/changes Status
Banking Act (BankA) • Create the possibility for cooperative banks to issue Adopted by Parliament
(participation capital of a participation notes. on 15 June 2018
cooperative bank) • Regulations on the rights of the holders of partici- Referendum deadline:
pation notes, the creation and use of general re- 4 October 2018
serves, dividend payments and the purchase of the
cooperative’s own participation notes.
Fund management companies/investment funds/
representatives of foreign collective investment schemes
Regulation Most important aspects/changes Status
Collective Investment • Introduction of a category of funds that are not sub- Hearing expected in
Scheme Act (CISA) ject to authorisation by FINMA. June 2019
(introduction of funds not • Limited Qualified Investment Funds (L-QIF) would
subject to authorisation) be reserved for qualified investors such as pension
funds and insurers.
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sponsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or
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