The countdown to the entry into force of the new Swiss Financial Services Act (FinSA) is underway.
It will only take a few months and then certain client advisors operating in Switzerland – primarily those of foreign financial service providers – will be legally obliged to be entered in a register of advisors.
Based on the provisions currently provided for in the draft Financial Services Ordinance (FinSO), it can be assumed that a large number of client advisors will ultimately be affected by this obligation to be entered in an advisor register.
Expenses and costs for client advisors should not be underestimated- Advisor Register Switzerland
An entry in a Swiss advisor register is made by a registration office approved by the Swiss Market Supervisory Authority (FINMA). An application must be submitted by the client advisor to the registration office. If it were simply a matter of publishing the name and company name of the client advisor concerned in a public register, this would not be a significant legal novelty.
However, the central aspect of this new obligation is that a client advisor must provide certain evidence before it can even be entered in a Swiss advisor register. Among other things, the client advisor must prove that he or she has sufficient knowledge of the legal rules of conduct according to FinSA and of the specialist knowledge required for the specific activity. For this, appropriate solutions are needed to keep the effort and costs for client advisors and the registration office within reasonable limits.
Challenge for client advisors to prove the necessary knowledge
In Switzerland, certain financial training courses such as AZEK and CFA are well known and widespread. Some of the larger banks also offer their employees very comprehensive internal training seminars and documentation. If a client advisor has such a recognised diploma that matches his activity, it can be assumed that the client advisor will at least be able to demonstrate the necessary specialist knowledge to the registration office. But what about the rules of conduct and what about foreign client advisors who do not have any diplomas known in Switzerland?
Standardised online tests as a remedy
A personal inspection on site in a test center would cause high costs. Standardized online tests appear to be more suitable and cost less. In order to be able to use standardized online tests to prove the necessary knowledge for foreign client advisors, it should be possible to verify that:
- the client advisor in question has taken the test himself/herself and has not had it done over or together with another person (authentication and authentication);
- he or she is comprehensively tested in all necessary aspects;
- a sufficient number of test questions is available; and
- the test cannot be repeated as many times as required to ensure a certain level of quality.
Chatbots as a possible solution?
Here, chatbots combined with video identification could be used. The test would then be carried out live by a chatbot and questions would not have to be limited to multiple choice questions – as is usually the case with online tests. To ensure authentic registration by the relevant customer advisor, video identification would be an option, which is already used in the context of AML checks.
BX Swiss is looking for suitable Regtech services
Interested Regtech companies who have suitable services on offer can contact BX Swiss directly at regtech@regservices.ch. They should describe the company, which solutions is offered in the Regtech area and attach a short presentation.
More information can also be found at www.regservices.ch/en
A brief summary of the regulations FinSa and FinIA can be found here.
Featured image credit: Edited from Freepik
