On 17 May 2013, the Swiss Financial Market Supervisory Authority (FINMA) published a newsletter setting out its interpretation of certain transitory provisions in connection with the partial revision of the Collective Investment Schemes Act (CISA) and the Collective Investment Schemes Ordinance (CISO). In the newsletter, a distinction was drawn between (a) financial intermediaries actively distributing funds to qualified investors in Switzerland before 1 March 2013, and (b) those who were not.