The Swiss Financial Services Act (FinSA)

The Swiss Financial Services Act (FinSA) entered into force in January 2020. With a transition period of two years, most of the requirements will be applicable as of January 2022.

FinSA mainly governs the provision of financial services as well as the offering of financial instruments and is intended to strengthen investor protection. In terms of content, FinSA is closely aligned with the European regulatory reforms and mainly covers the following areas:

Enhancement of investor protection
Transparency of financial products
Revision of organizational requirements for the provision of services

FinSA applies to financial services provided to clients domiciled in Switzerland as well as to financial services provided in or out of Switzerland e.g. to foreign domiciled clients.

What it means for you as our client

General information about client classification
FinSA establishes the following three client classes: “Retail (non professional)”, “Professional” and “Institutional” clients. Depending on the client classification, different levels of investor protection apply, in particular, with regard to information duties, assessment of suitability and appropriateness as well as documentation and reporting duties:

Retail (non-professional) clients: As a rule, clients who are not classified as Professional or Institutional are considered Retail (non professional) clients. This classification provides the highest degree of investor protection. In particular, it requires a detailed assessment of the suitability of the individual client’s investment, the provision of comprehensive information, and access to appropriate universe of financial instruments.

Professional clients: Professional clients are clients who possess the knowledge, experience, and expertise to make their own investment decisions and properly assess the risks incurred, such as pension providers (namely pensions funds), public entities, and companies with a professional treasury function. As a result, a lower level of investor protection applies to them but they have access to a broader financial instruments and services universe.

Institutional clients: Institutional clients include, inter alia, banks, insurance companies, and other financial intermediaries subject to prudential supervision in Switzerland or abroad. Given their structure, experience, and financial resources, these clients are considered highly sophisticated and less vulnerable. Therefore, the most protective measures under FinSA would not apply to them.

In line with the abovementioned FinSA requirements, Credit Suisse classifies clients as “Retail (non professional)” clients, “Professional” clients and “Institutional” clients. You may contact your relationship manager if you are unsure about your client classification or take a look at this factsheet (PDF) for further information.
Risk Information

Transactions with financial instruments comprise opportunities but also bear risks. It is therefore important to understand these risks before using any financial service.

The following brochure “Risks Involved in Trading Financial Instruments” of the Swiss Bankers Association (SBA) provides general information about typical financial services and describes the characteristics and risks of financial instruments:

Risks Involved in Trading Financial Instruments (PDF)

Please familiarize yourself with the information in this brochure prior concluding a contract or investing into a financial instrument and contact your relationship manager if you have any questions.

You can also obtain a physical copy of the brochure from your relationship manager.

Cost Information

In relation to the provision of financial services, costs and fees may be incurred both by Credit Suisse and third parties. We distinguish between costs and fees that are charged directly to your account and financial instrument costs.

For Credit Suisse service fees please consult the following price lists:


Clients of Credit Suisse (Switzerland) Ltd.	Clients of Credit Suisse AG
Safekeeping, securities transactions & ancillary services (PDF)	Safekeeping, securities transactions & ancillary services (PDF)
Special products transactions (PDF)	Special products transactions (PDF)

Please note that the safekeeping and transaction fees disclosed therein apply to clients without a portfolio management and/or advisory agreement. You can also obtain a physical copy of the price lists from your relationship manager. If you sign a portfolio management and/or advisory agreement different pricing models apply. You will obtain respective price lists from your relationship manager prior agreement closing or strategy change.

An overview of costs and fees, including external fees, financial instrument costs and charges for foreign exchange transactions, is provided in the following cost addendum:

External fees, financial instrument costs & charges for foreign exchange transactions (PDF)

Information about the effective costs and fees of your financial transactions can be obtained from your relationship manager upon specific request.

Advisory Minutes

Where Credit Suisse provides investment advice for financial instruments, the suitability assessment is documented in the advisory minutes, specifying the advice given and how that advice meets, among other things, the client’s objectives and personal circumstances, including the client’s attitude to risk and ability to bear financial loss. The advisory minutes also include the relevant details of the client meeting (e.g. meeting participants and initiator of the meeting) as well as information about the financial instruments discussed and the reasons for each recommendation.

As a retail client the advisory minutes will be send to you automatically after each contact concerning investment recommendation with the Relationship Manager or Investment Advisor. The dispatch for professional clients will only be executed on demand from the client. Professional clients have the possibility to waive the right for creating and receiving advisory minutes.

The scope for advisory minutes are all advised retail and professional clients, when the service is provided from Switzerland. All advised transactions and all recommendation types (i.e. buy, hold, sell, not to buy) for financial instruments are in scope of FinSA.
Key Information Document

With the introduction of FinSA, a Key Information Document (KID) must be made available to all retail clients if personal investment advice is provided on certain financial instruments.

The KID is a standardized document, which provides a brief and simplified overview about the key features, risks and costs of a financial instrument. In addition, it facilitates the comparison of different instruments.

In case of non-advised transactions, we only provide you with a KID if it has been made available by the manufacturer of the financial instrument. For transactions in the context of a portfolio management agreement, no KID will be provided.

You can also retrieve these KIDs – if provided by the manufacturer – via our following website:

credit-suisse.com/kid
Best Execution

Credit Suisse has established Best Execution arrangements for retail and professional clients that describe the principles, duties, and responsibilities to take all sufficient steps to systematically obtain the best possible result when either directly executing transactions on clients' behalf or transmitting client orders to intermediaries for execution.

Best Execution Policy (PDF)
Conflicts of Interest

Our Conflicts of Interest Policy

The summary of our Global Conflicts Policy below outlines how we will manage actual and potential conflicts of interest that may arise through the provision of services to you.

Download Conflicts of Interest Policy (PDF)
Client served by an external asset manager

If you have decided to entrust your assets to an external asset manager (EAM), Credit Suisse acts as a custodian bank in cooperation with EAMs.

Your EAM would act solely based on your instructions and is neither an employee nor a representative of Credit Suisse. Please be aware that Credit Suisse cannot take responsibility for the regulatory compliance of the EAMs it cooperates with.

For clients managed by an EAM some particularities apply (not exhaustive):

EAMs will also classify clients into institutional, professional and retail clients and will, depending on the classification, obtain information on clients’ knowledge and experience with respect to financial instruments. When providing investment advice or making investment decisions, the EAM (and not Credit Suisse) is responsible for matching financial instruments with clients’ suitability and appropriateness profiles. For the avoidance of doubt, Credit Suisse will not perform any suitability and appropriateness assessment and, thus, will not check the client’s knowledge and experience, ability to bear financial risks and investment objectives in situations where clients are served by an EAM and Credit Suisse acts a custodian bank.

Furthermore, depending on the above-mentioned classification, when providing investment advice for specific financial instruments, the EAM should provide information on financial instruments prior to an investment decision and must document the advice given (advisory minutes).

EAMs generally will disclose costs and related charges prior to an investment decision or prior to concluding a portfolio management agreement, taking into account the client’s classification and services provided. FinSA investment report will encompass only Credit Suisse costs. The EAM should also inform clients additionally about their own costs and charges.
Additional information
Credit Suisse is committed to providing you transparency on all aspects of your relationship with us. Please refer to your relationship manager if you would like additional information, in particular with regard to:

Composition, valuation and development of the portfolio regarding the management of your assets;

Development of the portfolio in respect of the management of your custody accounts;

Costs associated with the financial services;

Amounts of remuneration effectively received in accordance with the Financial Services Act;

Documentation established in the course of the client relationship (e.g. copy of client file).
Satisfaction

Credit Suisse is committed to providing you with the highest level of service. If you are not entirely satisfied, we urge you to contact us at your earliest convenience so that we can seek to take all steps necessary to rectify these concerns.

The most efficient way to address any concerns you have is to contact your relationship manager, who will in turn strive to answer any questions and resolve any concerns you might have.

You can also write to us at:

Credit Suisse
Client Feedback specialist unit
YSPI
8070 Zurich, Switzerland
Fax +41 (0)44 333 62 99

Further information

You can also refer your case to the Swiss Ombudsman Service at any time, in particular if our final response was not satisfactory:

Swiss Banking Ombudsman
Bahnhofplatz 9
Postfach
8021 Zurich, Switzerland
Phone: +41 (0)43 266 14 14

The procedure as well as all relevant information can be found online at www.bankingombudsman.ch