On 13 January 2025, the Swiss Financial Market Supervisory Authority (FINMA) released updated guidance on reporting requirements for collective investment schemes (CIS). This guidance note by FINMA’s Asset Management division, provides detailed instructions for financial intermediaries on how to report data related to investment funds, including liquidity, leverage, and counterparty risks, as part of an annual supervisory framework. The guidance aims to enhance systemic risk identification and improve oversight of fund management practices.
The updated rules apply to all Swiss funds with net assets exceeding CHF 500 million and foreign funds managed by Swiss entities meeting the same threshold. These funds must provide detailed reporting, focusing on funds employing alternative investment strategies such as hedge funds, private equity funds, and commodity funds. Smaller funds below the CHF 500 million threshold are excluded from the reporting requirements.
The reporting obligations cover banks, securities firms, insurance companies, and fund management companies operating within the scope of the Swiss Financial Institutions Act (FinIA), the Swiss Banking Act (BA), and the Swiss Insurance Supervision Act (ISA). These entities must:
- Submit annual data reports on exposures, liquidity, leverage, and counterparty risks for funds under their management.
- Provide data on both Swiss-domiciled funds and foreign funds managed from Switzerland that surpass the CHF 500 million net asset threshold.
- Ensure data submission adheres to the cut-off date of 31 December, with a final submission deadline of 31 March the following year.
The guidance also outlines technical requirements, including the use of FINMA-provided Excel templates or XML Schema for reporting, and specifies the inclusion of key fund identification details such as net fund assets, leverage calculations, and liquidity risk metrics.
The updated guidance is part of FINMA’s efforts to align with international standards, addressing data gaps in risk reporting for collective investment schemes. By collecting risk-based data, FINMA seeks to improve the supervision of fund management, enabling a more accurate assessment of systemic risks within the Swiss and global financial ecosystems.
FINMA may exempt certain funds from reporting if they pose minimal leverage or financial stability risks. The new framework ensures that data collection focuses on funds with significant potential impact, streamlining oversight while maintaining regulatory rigour.
The updated reporting requirements takes immediate effect, with the first reporting cycle starting on 1 January 2025 and ending on 31 December 2025. Entities are required to submit their reports to FINMA by 31 March 2026.
The updated FINMA guidance reflects a comprehensive approach to strengthening the regulatory oversight of collective investment schemes. By focusing on larger funds and high-risk strategies, the initiative enhances FINMA’s ability to monitor systemic risks and ensure the stability of the financial market in Switzerland. Financial intermediaries must now align their reporting practices with the updated requirements to remain compliant.
(Source: https://www.finma.ch/en/documents/, https://www.finma.ch/en/~/media/finma/dokumente/dokumentencenter/myfinma/2ueberwachung/erhebung-asset-management/guidance-cis-reporting.pdf?sc_lang=en&hash=F2494FE22B179F6017B47AB2F99A2AE6)
