Dear Clients,
We would like to inform you of recent developments in the implementation of the Swiss Financial Market Infrastructure Act (FINMASA).
In order to ensure transparency in its practices, the Swiss Financial Market Supervisory Authority (FINMA) issued FINMA Circular 2025/21 at the end of last year, which specifies FINMA’s expectations regarding the content of the rules of conduct set out in the LSFin. The general terms and conditions of the management mandate and advisory mandate for the entire portfolio you have entrusted to us have been updated to reflect these requirements and incorporate the provisions of FINMA Circular 2025/2. The updated version of the general terms and conditions will be sent to you shortly.
Vision Asset Management SA always strives to provide the best services to its clients and applies a principle of open architecture. Consequently, when selecting or offering financial instruments to its clients, it considers and proposes financial instruments managed or advised by Vision Asset Management SA and/or third-party financial instruments, as defined by FINMA Circular 2025/02 in sections 23 and 24.
Vision Asset Management SA takes appropriate measures to ensure that clients do not bear excessive costs as a result of investments in such financial instruments. Where applicable, Vision Asset Management SA ensures that clients’ interests are protected in the event of conflicts of interest, in particular by only promoting investment in financial instruments that it manages according to objective criteria.
Therefore, when proposing or incorporating this type of instrument as part of asset management or investment advice, Vision Asset Management SA may be faced with conflicts of interest.
We would also like to draw your attention to the following applicable requirement of FINMA Circular 2025/2, which we have taken into account:
Within the framework of the mandate you have entrusted to us, the management strategy may lead to the portfolio holding positions that present an unusual concentration risk, as defined in sections 9 to 12 of the circular:
In concrete terms, this risk materialises when the assets under management present:
- a concentration of 10% or more in an individual security, and/or
- a concentration of 20% or more in aémetteur.
When a position in the portfolio reaches these thresholds, the portfolio is exposed to specific risks (e.g. market risk, credit risk, currency risk) associated with the overweighting of an asset or issuer.
It is important to note that these rules do not apply to concentrations arising from collective investment schemes, which are subject to regulatory provisions on risk diversification.
By providing this information, you acknowledge and accept that, in the pursuit of optimal returns, the portfolio may include positions with this type of concentration and you accept the risks involved. However, if you wish, you may choose to exclude such exposures from your portfolio or specify diversification requirements for your portfolio by indicating a maximum percentage for certain securities or issuers.
We hope that you find the information contained herein useful and remain at your disposal should you have any questions regarding FINMA Circular 2025/2.
We hope you receive this communication in good order and remain, yours faithfully,
Vision Asset Management SA
1 FINMA Circular 2025/2 is available on the FINMA website.(https://www.finma.ch/en/documentation/circulars/).