Everyone knows the “onion principle” when it comes to staying warm in the mountains. In the morning you get up early to conquer the freshly prepared ski slopes in the freezing cold. Packed snug and warm with your day pass in your pocket, you make your first run. After a few descents you already start to sweat and the first layer comes off. During the coffee break, the weather takes a turn and layers come on and off to suit. After the final descent all superfluous layers are jettisoned as we enter the warmth of the après-ski bar…
So what does this have to do with FIDLEG/FINIG and yourself?
The new regulation will come into force in January 2020. We offer you the ideal tool so that you feel neither cold nor stifled by the new regulations, so you can continue to master your everyday work professionally and don’t get caught neglecting your customers: ONE CRM. We offer you the right “layer” for every FIDLEG/FINIG requirement.
FIDLEG/FINIG requirements & our solutions for your daily business
To illustrate the forthcoming changes, we focus on a few passages from the Regulation and explain our corresponding solution:
Customer segmentation. According to FIDLEG, a differentiation of customer segments is required (FIDLEG Art.4: “a. private customers; b. professional customers; c. Institutional clients”). ONE PM supports you in the assessment and documentation of this client segment and provides the documentation and protocol for a possible opting-out/in process (FIDLEG Art.5: “Wealthy private clients and private investment structures established for them can declare that they wish to be regarded as professional clients (opting out)”).
Adequacy and suitability of financial services. Recording the relevant knowledge and experience of your clients in order to comply with the adequacy test in the advisory and investment process is possible with the ONE PM platform and thus fulfils the corresponding article of FIDLEG (FIDLEG Art.11: “A financial services provider, […] must inquire about the knowledge and experience of its clients and before recommending financial instruments check whether they are appropriate for the client”). In addition, ONE PM offers E questionnaires for the assessment of risk capability/tolerance (“Suitability”, FIDLEG Art.17 para.1+2), which ensure that the risk profile meets the requirements of the suitability test (“Appropriateness”, FIDLEG Art.17 para.3 / FIDLEG Art.12).
Documentation and accountability. The customer relationship must be documented (FIDLEG Art. 15), which is fully supported by the ONE PM CRM solution (in particular contacts, journal, mandate management). A corresponding e-dossier is also provided to meet the obligation to provide the data stored to the customer (on request, FIDLEG Art. 16). The statement of accounts comprises several documentations: Order management & documentation to demonstrate “best execution” and equal treatment of clients (FIDLEG Art.19 para 1a / FIDLEG Art.17), investment reporting (FIDLEG Art.19 para 1b-c) and gross / net performance calculation (FIDLEG Art.19 para 1d). In accordance with Art. 19 para. 2a+b, accounting is carried out via a “permanent data carrier” at the time intervals agreed with the client and on their request. ONE PM provides the infrastructure for providing storage and access to automatically generated customer investment reports.
Transparency and diligence in customer orders. In order to comply with the relevant article (FIDLEG Art. 20: “Financial service providers must have procedures and systems in place to process customer orders which: a. are appropriate to their size, complexity and business activity; and b. ensure the interests and equal treatment of customers”), ONE PM offers the necessary pre-trade checks (compliance, appropriateness, suitability) and a collective order template in the investment process. In addition, a customer journal can be created at the push of a button to document the customer relationship, which can also be used to document the avoidance of conflicts of interest. ONE PM thus also complies with FIDLEG Art. 28 (“Financial service providers must document which of their financial services have or may have conflicts of interest”). According to FIDLEG Art. 97, a copy of the customer’s dossier must be made available to the customer on a durable data carrier at any time, which ONE PM satisfies with a customer booklet that can be retrieved at any time.
Basic information sheet for financial instruments. According to FIDLEG Art. 58, this information must be recorded in advance. ONE PM provides a security database for storing KIIDs (Key Investor Information Document) and also offers templates for basic information sheets for the most important financial instruments.
“Within two years” – get started on time, we’ll support you!
Pursuant to Art. 112, the FIDLEG/FINIG Ordinance will enter into force on 1 January 2020. The transitional provisions stipulate that client segmentation and rules of conduct must be complied with by financial service providers and the necessary knowledge by client advisors within two years of this Ordinance coming into effect. As mentioned above, you will be required to make a number of important changes. We therefore recommend that you start thinking about and organising your business now. Take advantage of our special FIDLEG/FINIG “ONE CRM” offer, with which – for an unbeatable SFR 2,500 per year – your entire company can benefit from the ONE PM solution to satisfying the coming regulations. We look forward to supporting you!