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.