Briefing for Switzerland

Updated documentation requirements for foreign collective investment schemes offered and marketed in Switzerland.

Further amendments to documentation for foreign funds marketing an offering in Switzerland will come into effect from 1 January 2022 following the entry into force of sections of the Financial Services Act, the Financial Institutions Act and the revised Collective Investment Schemes Act.

Distribution Agreements

The Swiss representative is no longer required to be a contractual party to Swiss distribution agreements as of January 1, 2022. Foreign funds can expect to be contacted by their Swiss Representative to update any Swiss distribution agreements to reflect this change.

Swiss Country Supplement

A revised template Swiss Country Supplement has been issued by the Asset Management Association in Switzerland. There is no regulatory deadline by when it should be implemented, but it must be done together with the next update of the Swiss Prospectus with FINMA following 1 January 2022. Local counsel will need draft the relevant update.

If you have any questions in relation to the above please contact a member of the Foreign Registrations Team or your usual contact at Dillon Eustace.