FINMA authorisation process for portfolio managers and trustees

Overview of the authorisation process

Portfolio managers and trustees are now subject to the supervision by a Supervisory Organisation (SO) and are required to obtain authorisation from FINMA. When submitting the authorisation application, portfolio managers and trustees must provide evidence that they are supervised by an SO. FINMA has started the authorisation process - the submission of both notifications and authorisation applications can be handled electronically via the EHP survey and application platform.

Step 1: Self-registration  •  When: immediately

Portfolio managers can immediately self-register via the FINMA website to gain access to the EHP. Within the context of this process, it is required to appoint at least one «Authorisation Coordinator» (AC). This person can authorise other people from the institution for the EHP. After the completion of the registration process, FINMA will review the registration and approve the appointed AC. The EHP access information will then be sent both via email and regular mail.

Important: the FINMA approval that follows the self-registration does not mean that the notification has been performed nor that the authorisation has been granted.

Step 2: Notifying FINMA  •  When: by 30 June 2020 at the latest

After having received the EHP access data, the AC is required to appoint on the platform a person that will fill the «Manager» role. The Manager then prepares the registration form and appoints a «Notification Coordinator». Only the Notification Coordinator or his/her deputy are allowed to notify FINMA by 30 June 2020.

It is recommended to appoint a qualified (third party) person for the role of the Notification Coordinator in order to ensure correct entries and avoid unnecessary queries.

Steps 3 - 5: Affiliation with an SO and submission of the authorisation application  •  When: presumably from mid-2020

After having notified FINMA, an authorisation application needs to be submitted. However, before submitting the authorisation application to FINMA, portfolio managers are required to affiliate with an SO. When submitting the authorisation application, portfolio managers and trustees must provide evidence that they are subject to supervision by an SO. However, the affiliation with an SO will only be possible as soon as the SO will be approved by FINMA; by mid-2020 at least two SO should have received such approval from FINMA.This means that the application can be submitted after mid-2020, namely after the affiliation with the SO. Therefore, the remaining time is ideally used for thorough preparation.

It is also worth ensuring regulatory expertise in connection with the preparation of the authorisation application in order to avoid potential delays.

Further information on the FINMA authorisation process and on how to delegate the process to gwp as an expert third party for the notification resp. the authorisation application is provided here.


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