Deadlines

Regarding the deadlines you have to meet, you will find them below:

For companies that started their portfolio management or trustee activity before 1 January 2020, the deadlines are as follows:

31 January 2021
Deadline for joining one of the ombudsmen recognized by the Federal Department of Finance
List of recognized ombudsmen
31 December 2021
Last deadline to adapt its documentation and organization to the FinSA rules of conduct and organizational rules

This period does not apply a priori to trustees, unless they provide financial services within the meaning of FinSA.

31 December 2022
Deadline for filing the application for the FINMA authorization.

In order to apply to the FINMA authorization, you must first have obtained your affiliation to OSIF (see point 4. above). We therefore recommend that you give OSIF access to your file on the EHP platform (see point 2. above) by 30 June 2022 at the latest to give it time to process your application.

For companies that started their activity during 2020, the deadlines are as follows:

They may continue to operate until a decision has been taken on the FINMA authorization if:

  • Immediate announcement to FINMA
  • Immediate compliance with authorisation conditions
  • Immediate affiliation to the ARIF SRO
6 July 2021
Deadline for filing the application for the FINMA authorization.

In order to apply to the FINMA authorization, you must first have obtained your affiliation to OSIF (see point 4. above). We therefore recommend that you give OSIF access to your file on the EHP platform (see point 2 above) by 31 March 2021 at the latest to give it time to process your application.

For companies that wish to start their portfolio management or trustee activity in 2021: In this case, the law does not provide for a transitional period. These companies may only start their activities if they are affiliated to the OSIF and authorised by FINMA.
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