SFAMA News Edition 01/2019

2SFAMA News Spring 2019

Table of Contents

Introduction

In Focus

Latest news

Fund markets

National environment

8th World Funds Day The SFAMA is looking for reinforcement

From a portfolio-centric mindset to a focus on the investor and the real economy

Deadlines coming up! Financial Market Infrastructure Ordinance

Key data on the international fund business Swiss fund market in 2018 Decrease in assets under management year-on-year Equity markets in 2018 Swiss ETF market in 2018 SFA ARI® ESG funds in vogue for various reasons Share of ETFs in institutional portfolios The world’s ten largest funds Statistical report on AIFs Key figures on the Swiss financial center

FinSO/FinIO: response to consultation Consultation on amendments to AEOI legal basis Federal Council wants to further improve framework conditions for blockchain/DLT Daniela Stoffel appointed State Secretary for International Finance Benjamin Gentsch elected to FINMA Board of DirectorsNew Operating Principles for Impact Management FINMA Guidance “BREXIT: Recognition of UK derivatives regulations” FINMA Guidance “BREXIT: Recognition of UK derivatives regulation“ Ausgabe von Immobilienfondsanteilen – Aktualisierung der Fachinformation Überarbeitung der AIA-Wegleitung Praxisentwurf MWSTG Kryptowährungen State Secretariat for International Finance

44

5

66

78

101012131414151515

161617

17

171717

17

17

181818

3SFAMA News Spring 2019

International environment

SFAMA activities

Swiss Fund Data

Interesting reading

LIBOR replacement EU-Organe einigen sich auf ESG-TransparenzregelnDisclosure of ESG matters by issuers EFAMA and AMIC publish joint report on liquidity stress tests in investment funds Pepp agreement provides pep to fund industry, says EFAMA Crypto-assets need common EU-wide approach to ensure in-vestor protection Revised Guidelines on outsourcing arrangements

Members Specialist committees Upcoming events

Swiss Fund Data community still growing

Friends of Funds Federal Council initiates consultation on partial revision of Banking Act Annual GIPS standards notification form: deadline is 30 June 2019 FINMA guidelines on conducting the regulatory auditIntroducing a comprehensive cost indicator for fundsCoredataresearch: Five Key Challenges Facing Asset Managers in 2019 EFAMA welcomes sustainability rules but warns on timefra-me Country Sustainability Ranking Update Inspiring Investment Partnerships to Achieve Global Goals Report on Pension Funds Statistics and Trends 2018 Wo die Gelder unserer beruflichen Vorsorge steckenSKSF Jahresbericht 2018 BVI veröffentlicht neue Broschüre für Vermittler

Useful informations and adresses

19191919

19

20

20

212122

23

2424

24

252525

25

252526262626

27Impressum

4SFAMA News Spring 2019

8th World Funds DayThe first World Funds Day took place on 19 April 2012. Why this date in particular? The answer is that the Amsterdam-based merchant A. van Ketwich was born on 19 April 1744, and in 1774 he was the first to bring together a broad group of investors who bought units in a type of fund called Eendragt Maakt Magt (Unity Fosters Strength). This fund then invested in bonds issued by various governments, in banks, and in West Indian credits. A few years before, numerous British banks had been plunged into insolvency after granting excessively large loans to a small number of colonies. Van Ketwich recognized that broad diversification of risk was crucial in determining investment success and, as such, can be regarded as the father of the philoso-phy of fund investing, so to speak. World Funds Day gives both providers and associations (SFAMA included) a platform to present information on the basic principle behind investment funds.

The SFAMA is looking for reinforcement To meet the upcoming regulatory challenges we are looking for a new Senior Legal Counsel for our office in Basel.Job advertisement on www.sfama.ch/en

Introduction

5SFAMA News Spring 2019

In Focus

From a portfolio-centric mindset to a focus on the investor and the real economy

The asset management industry has many facets. It plays a key role in providing security and stability for pension schemes, helping people to achieve their savings goals, and ensuring that the economy is funded efficiently, but it needs to change in order to perform these functions. It has to move away from thinking purely in terms of portfolios and products and devote itself systematically to serving investors and the real economy.

The financial industry manages assets of more than USD 70 trillion worldwide. In Switzerland, the sector employs some 200,000 people and manages institutional assets totaling roughly CHF 2,200 billion. Asset managers hold around 25% of listed companies’ bonds and nearly 40% of their shares in circulation. This is an important and welcome alternative to funding via classic bank loans. As impressive as these figures are, they are not the whole story. The financial industry cannot be self-sustaining – it can only survive by serving investors and the real economy.

We can therefore conclude that generating returns is not the whole point of asset management but just an es-sential prerequisite to justify its existence. The industry must therefore stop thinking purely in terms of outper-forming a benchmark being its raison d’être as this in itself rarely has anything to do with clients’ real needs.

We must of course not underestimate or, worse still, deny the importance of returns. Rather, we must put in-vestors and their individual needs (back) at the center and systematically gear our actions to serving them. This entails a paradigm shift in the way asset management operates – and not just as far as private clients are concerned. It is important to know the clients’ real investment goals, such as funding a pension or buying a home or car, since these define the key parameters for investing the available assets. Asset managers also have to understand “soft factors”, i.e. views and preferences stemming from the client’s religion, political allegiance or worldview.

The financial industry often tries to sell solutions rather than products. This is undoubtedly the right approach, but it has to be remembered that solutions must always be tailored to the individual situation rather than ba-sed on averages. Asset managers must align their objectives and risk analysis with their clients’ needs. This focus on the individual gives rise to a number of challenges: reducing complexity, producing understandable information, improving transparency, and unraveling the dense mesh of regulation to make sure that asset managers can genuinely provide their clients with bespoke advice.

Markus Fuchs Managing Director of the Swiss Funds & Asset Management Association SFAMA

6SFAMA News Spring 2019

Deadlines coming up!In this section we highlight any significant deadlines coming up over the short term. This is aimed at assisting your planning, but it is by no means an exhaustive list.

Financial Market Infrastructure Ordinance (Jan 1, 2016 – Aug 31, 2020)The transitional provisions regarding the Financial Market Infrastructure Ordinance of 25 November 2015 are set out in Title 4 FMIO. In the absence of any ruling to the contrary in the specific transitional provisions, the new provisions apply from the entry into force, i.e. from 1 January 2016.

Latest News

7SFAMA News Spring 2019

Fund Markets

Key data on the international fund businessThe rise in global fund volumes seen in the second quarter of 2018 continued in the third quarter, albeit to a somewhat lesser extent. As at the end of September 2018, the newly calculated fund volumes stood at EUR 46.6 trillion, up 2.1% quarter-on-quarter and 6.6% for the six-month period. Funds of funds accounted for EUR 3.36 trillion. In 2014, working in conjunction with the IIFA (International Investment Funds Associa-tion), EFAMA incorporated new fund types such as ETFs, institutional funds, and hedging products into the universe covered, and this resulted in a massive increase in both fund volumes and product numbers. Direct comparisons with earlier data can therefore only be made with figures from the beginning of 2015 onward.

Positive development in global fund volumes across the boardNo country or region ended Q3 2018 in negative territory in EUR terms. The EUR appreciated only slightly against the USD during the quarter, which had little impact on the results. In the USA, the total volume was just below the EUR 22 trillion mark at the end of September 2018. According to the latest EFAMA report, a total of EUR 15.6 trillion was invested in funds in Europe.

2nd quarter 20183rd quarter 2018 Changes measured in local currencies

USA Europe Australia Brazil Canada Japan

Source: EFAMA International Statistical Release, December 2018

China

2114321982

3.2%

1555915583

1796 1799 1497 1484 1440 1489

0.2% 2.0% 2.9% 0.9%

1545 1577 1549 1579

4.1% 5.0%

Geographical trends in investment fund assets in Q3/18 (in EUR billions)

8SFAMA News Spring 2019

Global fund universe of 129,980 fundsThere was a further increase in the fund universe covered by EFAMA in Q3, and by the end of September 2018 it stood at a record high of 129,980 different products. This corresponds to an increase of 1,408 funds since the beginning of July 2018. The breakdown of products per fund category is as follows: equities 43%, bonds 20%, multi asset 17%, money market 11%, and others 9%.

Swiss fund market in 2018Swiss Fund Data AG, a subsidiary of the Swiss Funds & Asset Management Association SFAMA and SIX Swiss Exchange Ltd, has been publishing statistics for the Swiss fund market together with Morningstar Switzerland GmbH since 2014. The market data of the two companies are brought together and published by Swiss Fund Data AG in the form of public market statistics and via a monthly statistics subscription service. This offering is complemented by the regular market commentaries from SFAMA, which cover the develop-ment of the Swiss fund market.

Fund volumes around CHF 1,041.3 billionAccording to the statistics on the Swiss fund market, the total volume stood at CHF 1,041.3 billion at the end of December 2018, down around CHF 65.1 billion or 5.9% quarter-on-quarter. The figures are based on the FINMA approvals list and cover all funds under Swiss law as well as all foreign funds approved for distribution in Switzerland, including institutional unit classes

Scarcely any change in the international breakdownComparing the figures ascertained by EFAMA, both the USA and Europe showed relatively stable shares in the fund assets invested worldwide as at the end of September 2018. Australia remained in third spot with 3.9% and a respectable lead over the next two countries on the list – this year China and Japan with 3.4% each.

Geographical trends in investment fund assets by end of September 2018

Australia 3.9%

USA 47.1%

Europe 33.4%

China 3.4%

Japan 3.4%

Canada 3.2%

Others 2.5%

Brazil 3.2%

Source: EFAMA International Statistical Release, December 2018

9SFAMA News Spring 2019

Fund category

Equities

Bonds

Money Market

Asset Allocation

Others

Natural Resources

Alternatives

Real Estate

Volume 31.12.18

413.3

341.1

91.6

119.4

2.3

22.4

16.0

35.2

Overall change

- 52.4

+ 0.6

+ 15.5

- 10.2

- 0.7

- 1.1

- 5.0

+ 2.6

- 50.7

Volume 31.12.17

465.7

340.5

76.1

129.6

3.0

23.5

21.0

32.6

1092.0

Development of fund assets since January 2018

Source: Swiss Fund Data / Morningstar (in CHF billions

Broken down by asset class, equity funds still have the largest share with nearly 40%, followed by bond funds with around 32.5%. Asset allocation funds remain in third spot with approximately 11.5%.

Increase of 422 fundsAt the end of 2018, there were 9,824 funds approved for public distribution in Switzerland, a net increase of 422. Of these, 1,726 were funds under Swiss law (+84), and 8,098 were funds under foreign law (+338), the latter category being dominated by 5,409 Luxembourg-law products (+193).

The revised Collective Investment Schemes Act is continuing to bolster the market activities of many pro-viders, hence the net increase of 422 funds. Over the course of the year, 344 foreign collective investment schemes were newly approved, while six were removed from the register. A total of 165 Swiss-law products were newly approved, with 81 removed from the register. Of the 1,726 Swiss-law funds, 769 were approved by FINMA exclusively for distribution to qualified investors (please see also the table below).

Fund type /Fund domicile

Swiss FundsSwiss limited partnerships Securities funds Other funds for tradit. inv. Other funds for altern. inv.Real estate funds

Non-Swiss funds Luxemburg Ireland Other countires

Total Swiss and Non-Swiss (In brackets: funds for qualified investors) Source: FINMA (as of the beginning on January 2018)

Development of number of funds by type of fund / fund domicile

As of end-December 2017

As of end-December 2018

Changein the year 2018

164218

1371382

4560

776052161684860

9402

(715)(18)(0)

(657)(17)(23)

(715)

172619

1361455

5066

809854091857832

9824

(769)(19)(0)

(702)(21)(27)

(769)

+ 84+ 1- 1+ 73+ 5 + 6

+ 338+ 193+ 173- 28

+ 422

(54)(1)(0)

(45)(4)(4)

(54)

10SFAMA News Spring 2019

The ratio of foreign funds to collective investment schemes under Swiss law has remained fairly constant at around 4:1 over recent years. Luxembourg and Ireland are by far the largest foreign domiciles of funds appro-ved here in Switzerland. With a total of 7,266 products, their market share had increased by one percentage point at the end of 2018 to 90%. France remained in third spot, followed by Liechtenstein and Germany.

Decrease in assets under management year-on-yearIn line with market trends, the securities holdings in client custody accounts at Swiss banks were rather volatile over the course of 2018, reaching CHF 5.8 trillion at the end of December according the Swiss Na-tional Bank statistics published in February. This represents a drop of 6.3% from the near-record high of CHF 6.2 trillion seen at the beginning of the year and constitutes the 2018 low following the correction in the fall. According to the SNB’s monthly statistics, the securities holdings of non-resident clients fell by 8.3% to CHF 2.9 trillion. Resident clients’ holdings also fell, albeit by only 4.1% to CHF 2.9 trillion. At just under 50%, the share of non-resident clients in the securities holdings was roughly one percentage point lower than in the previous year.

Differing fund weightings for resident and non-resident clientsThe fund holdings of resident custody account clients fell by 2.5% to CHF 1,267 billion. Their non-resident counterparts had fund holdings totaling CHF 831 billion at the end of December, which translates into a drop of 6.8%. The trends in fund weightings over the course of the year were parallel for once. In the case of resi-dent clients, there was a steady increase from the 42.8% recorded at the beginning of the year to 43.5% by the end of December 2018. The figure for non-resident clients also rose and now stands at 28.9% (up from 28.4%).

Equity markets in 2018As the year began, all signs pointed to a continuation of the previous year’s trend. Experts were more or less unanimously positive, particularly in view of economic growth across all regions simultaneously. Forecasters had singled out the USA as a driving force due to tax breaks that helped companies to achieve exceptionally strong earnings growth. The US stock market was breaking records up until the fall, when things took a turn for the worse, and fears grew that economic momentum would start to ease sooner and more sharply than had previously been thought.

Category

Development of securities holdings

Domestic2017 2018

Foreign2017 2018

Total2017 2018

22

728

948

1302

34

0

3034

26

726

857

1267

32

0

2908

45

542

1493

895

165

0

3140

50

538

1311

831

147

0

2877

67

1271

2441

2196

199

0

6174

76

1264

2168

2098

179

0

5785

Money Market

Bonds

Equities

Collective investments

Structured products

Other securities

Total

Source: SNB, Monthly Statistical Bulletins (figures in CHF billions)

11SFAMA News Spring 2019

Uncertainty across a broad frontGlobal stock markets lost around 10% in the fourth quarter of 2018. December was one of the US market’s worst months since 1931. The source of the current, all-pervading uncertainty is quite clear: politics. A whole raft of (geo)political risks – some new, some familiar – have arisen since last spring.

Conflicts and Brexit Forecasters had paid too little attention (or none at all) to the geopolitical tensions increasingly preoccupying the markets, foremost among them the trade dispute between the USA and China. This caused problems for lots of companies, leading to the downward correction of some macroeconomic projections. If things continue to get worse, the global economy could be slowed down noticeably. The UK’s exit from the European Union is of similar importance, and it still faces some major hurdles. There are also bilateral conflicts between the USA and Turkey, Iran, and North Korea and challenges in Italy. On top of all this, the oil price has been highly volatile, first showing a sharp rise and then falling just as abruptly. Investor sentiment started to worsen dra-matically at the latest during the fall, when the International Monetary Fund lowered its growth forecasts.

Tech sector facing up to responsibilityWall Street’s enthusiasm for Silicon Valley also waned as the view took hold that the geeks need to finally grow up. Consumer electronics is no longer all about harmless apps. Progress in the field of artificial intelli-gence has significantly increased its reach. This opens up huge sales potential, of course, but it also means that the technology sector has to face up to a lot more responsibility. A good illustration of how the world’s leading firms are facing greater scrutiny is the fact that Apple became the first trillion-dollar company in history at the beginning of August 2018 but then lost 10% of its value in December solely due to a revenue warning.

No impressive returns on equitiesSwiss investors, who tend to bet on rising prices and thus invest primarily in equities and bonds from indus-trialized nations, had little to be thankful for in 2018. It was one of the worst years for the stock markets in the past two decades. The average return across all asset classes was well into negative territory, comparable with those in the years from 2000 to 2002, when the technology bubble burst. That said, it was much higher than in 2008, when the financial crisis broke out. In contrast to earlier years, however, not a single asset class was able to show a significantly positive return. In 2000, for example, commodity prices rallied, whereas European government bonds gained almost 9% in 2008. Among the few asset classes posting mostly small gains or at least no pronounced losses last year were bonds from governments with high credit ratings.

Marked rise in volatilityLooking at the situation on the equity and bond markets at the moment, there is no cause for concern, but things are hardly rosy. Negative factors include high equity volatility, which suggests falling prices – going down faster than up – and an inverted yield curve, indicating massive economic pessimism on the bond markets. At present, this inversion is pronounced but not yet extreme. The volatility, on the other hand, is remaining within a normal range, although the trend is pointing upward.

Developments in SwitzerlandThe Swiss economy expanded in the first half of 2018 more quickly than that of the neighboring eurozone as well as that of the USA, but gross domestic product fell by 0.2% in the third quarter. Six of the stocks in the Swiss Market Index (SMI) at least posted gains over the year as a whole if dividends are factored in. Insurance stocks that pay high dividends and defensive heavyweights fared comparatively well. The latter in particular helped the SMI, which contains the 20 largest companies in Switzerland, to outperform the broader Swiss Performance Index (SPI), which features a larger proportion of cyclically sensitive industrial firms. The year was especially disappointing for banking stocks due to the absence of a sustained rise in interest rates and the conflict between Italy and the EU over the former’s budget. Swiss equities nevertheless performed relatively well in comparison with other markets. The leading barometer, the SMI, lost just over 7% (including dividends).

12SFAMA News Spring 2019

Selective approachForecasters are looking ahead to 2019 with less optimism than they had a year ago. The risks emanating from geopolitical troubles and slowing economic growth dominate the banks’ outlooks. With growth still above trend, no one is really expecting a bear market, but weak figures mean that a less favorable environment is now priced in, leaving some scope for upside surprises. This year is sure to be a difficult one for investors due to political uncertainty alone. There is also a question mark over just how willing central banks are to tighten the monetary policy reins as this would risk choking the economy in the current environment. It would certainly make sense to check at this stage whether the portfolio risk chosen still tallies with the investment horizon and personal risk tolerance.

Europe -20 -10 0 10 20Switzerland (SMI) -7.1%France (CAC 40) -8.1%UK (FTSE 100) -8.8%Netherlands (AEX) -10.4%Sweden (OMX) -10.7%Europe (Stoxx 50) -11.3%Spain (IBEX 35) -15.0%Italia (MIB) -16.1%Germany (DAX) -18.3%

North and Latin AmericaBrazil (Bovespa) 15.0%USA (Nasdaq Composite) -2.8%USA (Dow Jones) -3.5%USA (S&P 500) -4.4%Canada (S&P/TSX Composite) -11.6%Mexico (IPC) -15.6%

Asia/PacificAustralia (S&P/ASX 200) -6.9%Japan (Nikkei 225) -10.4%Hong Kong (Hang Seng) -13.7%

Returns in percent (in local currencies)

The major stock markets in 2018

Sources: Bloomberg, Factset (NZZ of 03.01.2019), Onvista

Swiss ETF market in 2018The turnover of exchange-traded index funds was curbed slightly for the first time in 2012, but ETFs quickly re-sumed their success story the following year. Their turnover was down 13.7% year-on-year at CHF 100.5 bil-lion in 2018 due to negative stock market trends, but this is still a respectable level. At the end of the year, there were 1,453 different ETFs listed on the SIX Swiss Exchange, spread across 25 issuers. In terms of investment focus, products covering traditional equity markets were still out in front with a 61.2% share. Bond ETFs had a 22.1% share of the market with 321 products. ETFs for commodities and precious metals increa-sed in number by five products to 99, but they still only make up 6.8% of the market. As regards trade sizes, the median is still very low at CHF 15,500.

13SFAMA News Spring 2019

SFA ARI®

SFAMA launched the SFA ARI® in 2012 with a view to making it possible to compare the actual yields of lis-ted Swiss real estate funds at the product level. This indicator is based on the investment yield statistics and is calculated quarterly (January, April, July, October) by Swiss Fund Data AG on the basis of the respective annual reports.

The fund universe comprises the real estate funds listed on the SIX Swiss Exchange that make direct real estate investments in Switzerland, with Switzerland being their sole investment country. Funds of funds and Swiss funds that invest directly outside Switzerland are excluded.

The current investment yield as measured by the SFA ARI® stands at 5.58%. This figure is based on the an-nual reports as at 30 September 2018, representing an increase of 21 basis points over the previous quarter. Some 30 real estate funds with net assets totaling around CHF 33.9 billion were included in calculating the current figure.

Turnover and number of ETFs at SIX Swiss Exchange since year 2002

Turnover SIX Swiss Exchange

Number of ETFs on SIX Swiss Exchange

1‘600

1'400

1'200

1'000

800

600

400

200

0

160‘000

140‘000

120'000

100'000

80'000

60'000

40'000

20'000

02002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Turnover in CHF millions

Source: SIX Swiss Exchange

Number of ETFs

2013 2014 2015 2016 2017 2018

7 %

6 %

5 %

4 %

Development of the SFA ARI® since 2013

Source: Swiss Fund Data

(Q3)

14SFAMA News Spring 2019

ESG funds in vogue for various reasonsSustainable investing is nothing new, but it has only become fashionable in the last few years. It took time for the broader public to realize that it is possible to do good without losing out on returns. The efforts summed up under the banner of ESG (environmental, social, and governance) date back to the Victorian era. Even then, socially minded captains of industry understood that they could do good while also doing good business. Le-ver Brothers (later Unilever) built the workers’ village of Port Sunlight at the end of the 19th century to provide the people working at its soap factory with access to high-quality housing, healthcare, and education. The aim was to improve their welfare and thus ultimately their productivity.

Nowadays, ESG investing is well on the way to gaining mainstream status, and this is reflected in steady growth in retail funds focusing on sustainability. This impressive development stems from the fact that in-vestors are increasingly concerned about what their money is used to finance and thus ever keener to invest in something good or at least avoid investing in anything bad. Incorporating ESG factors into the investment process can reduce risks and open up return opportunities as companies with good ESG management are better protected against crises and likely to be more profitable over the long term. A broad analysis of aca-demic studies into emerging market equity investments confirms that taking account of ESG criteria in stock selection has a particularly positive impact on the risk/return profile.

Contrasting approaches The term “sustainable investing” covers a whole host of approaches that differ considerably with regard to investors’ motivation and the influence ESG factors have on portfolio construction. In Europe, the largest volumes are invested in exclusion strategies, which rule out investments in controversial sectors such as defense, genetic engineering, and nuclear power. Engagement strategies, meanwhile, aim to bring about im-provements in companies with a negative environmental and social impact through dialog and by exercising voting rights. The best-in-class approach has been around for some time and involves carrying out a separa-te ESG analysis independently of the financial analysis. Only companies with a sufficiently high ESG rating are considered for investment. Thematic strategies have an even greater influence on portfolio construction. They invest strategically in companies whose products deliver solutions for the sustainable development of a particular sector. Impact investing also favors sustainable development solutions, but it places the focus clearly on environmental, social, and ethical goals.

Passive ESG investments now availablePassive investment vehicles geared to ESG have appeared more recently. Many of them target minimal de-viation in the risk/return profile relative to conventional benchmarks. This creates a weakness in that their portfolio composition does not differ much from that of the benchmark, which limits their ability to meet the ideological needs of institutional investors in particular.

Share of ETFs in institutional portfoliosA survey by Greenwich Associates reveals that the percentage of ETFs in the portfolios of institutional inves-tors that employ them doubled to 15% in 2018. Some 127 institutional investors took part in the survey. The findings show that this growth is attributable to three main factors:

• Thanks to their speedy trade execution, scope for broad diversification in a single transaction, and high liquidity, ETFs are a flexible tool for portfolio construction.

• Investors seeking low-cost access to certain markets continued to shift money out of actively managed strategies and into index-tracking vehicles last year. This led to increased inflows into ETFs, which 84% of survey respondents cited as their favored instrument for indexed investments. This trend is likely to conti-nue in 2019.

15SFAMA News Spring 2019

• 44% of respondents said that they viewed ETFs as a significant form of ESG investment. Almost half expect that over 50% of their total assets will be managed in accordance with ESG criteria within the next five years.

The average share of ETFs in bond portfolios doubled to 20%. ETFs also doubled their average share of equity portfolios to almost 28%.

Smart beta strategies remain a dependable driver of growth and demand for ETFs. Overall, two thirds of the survey participants invest in factor-based products or smart beta ETFs.

The world’s ten largest funds According to Morningstar’s database, the ten largest funds in the world had combined assets of EUR 2.35 tril-lion at the end of December 2018. Vanguard occupies the top three spots, and its Vanguard Total Stock Mar-ket Index Fund is in first place with assets of EUR 587 billion.

Statistical report on AIFsThe Paris-based European Securities and Markets Authority (ESMA) recently presented its first statistical report on alternative investment funds (AIFs) domiciled in the EU. The report places the total value of the category at EUR 4.9 trillion at the end of 2017, almost a third of the total volume of assets held in EU funds. It is based on data from 26,378 AIFs, covering 80% of the market, and will be published annually from now on.Funds of funds make up 16% of the category, followed by real estate funds with 11%, hedge funds with 5%, and private equity vehicles with 4%.

According to the report, most AIFs are sold to professional investors (81%), but private investors neverthe-less play an important role, particularly in funds of funds and real estate funds.

ESMA states that the data analysis highlighted some issues requiring further attention, including classifica-tion, while the liquidity mismatches identified among real estate funds, with their significant share of retail investors, indicate potential risks.

Key figures on the Swiss financial centerTwice a year, the State Secretariat for International Finance publishes up-to-date figures on Switzerland as a location for financial services. This useful summary publication is available for download and can also be ordered free of charge in a handy booklet format.http://www.sif.admin.ch Documentation

16SFAMA News Spring 2019

National Environment

FinSO/FinIO: response to consultationThe consultation on the Financial Services Ordinan-ce (FinSO) and the Financial Institutions Ordinance (FinIO) started on 24 October 2018 and ran until 6 February 2019. The annexes to both ordinances also entail extensive adjustments to the CISO and other ordinances.

The Executive Board has been representing the in-terests of the fund and asset management industry in this process. It has analyzed the consultation do-cuments in detail and drafted a response, aided by four working groups:

• WG 1 (Point of Sale)• WG 2 (Documentation)• WG 3 (Authorization and Supervision)• Roundtable for representatives (Geneva)

Key issues raisedThe Executive Board followed a pragmatic ap-proach with the aim of identifying the issues that are especially problematic for the fund and asset management business. This was communicated to the working groups. As a result, issues specific to individual institutions were not generally included in the responses.

The following key issues were identified:• Classification of pure “fund distribution” as a fi-

nancial service (Art. 3 para. 1 FinSO)• More precise definition of offering when appro-

ached by clients on their own initiative (Art. 3 para. 3bis [new] FinSO):

• Clarification of prospectus requirements for collec-tive investment schemes (Art. 43 et seqq. FinSO)

• No special rules on KIDs for collective investment schemes (Art. 80 et seqq. FinSO)

• No conflict with duties set out in CISA (Art. 95 para. 3 FinSO)

• Alignment of transition periods (Art. 103 et seqq. FinSO and CISO)

• Clear rules on delegation of duties (Arts. 9, 17, 32, and 48 FinIO and Art. 12b CISO)

• Duties of asset managers of collective invest-ment schemes and fund management compa-nies (Arts. 31 and 47 FinIO)

• Listing of unit classes (Art. 40 para. 5 CISO) and gating (Art. 109 CISO)

Response submittedThe Executive Board finalized the response and submitted it to the Federal Department of Finance (FDF) on time on 6 February 2019. SFAMA’s res-ponse can be found here (only available in German):https://www.sfama.ch/en/regulation/finsa-finia-center/consul-tations-regulations/statement-sfama?set_language=en

Consultation on amendments to AEOI legal basisDuring its meeting on 27 February 2019, the Fede-ral Council initiated the consultation on the revision of the Federal Act and Ordinance on the Internatio-nal Automatic Exchange of Information in Tax Mat-ters (AEOI). The revision is intended to implement recommendations put forward by the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum).https://www.admin.ch/gov/en/start/documentation/media-re-leases.msg-id-74136.html

17SFAMA News Spring 2019

New Operating Principles for Impact Management The Swiss financial sector welcomes the impact investing principles developed by the International Finance Corporation (IFC). This is the outcome of a consultation among more than 100 members of the association Swiss Sustainable Finance (SSF). The results were discussed at a meeting of the partner organizations IFC and SECO in Bern. https://www.admin.ch/gov/en/start/documentation/media-re-leases.msg-id-73730.html

FINMA Guidance “BREXIT: Recognition of UK derivatives regulations”FINMA has published its new Guidance 01/2019“BREXIT: Recognition of UK derivatives regulations”. https://www.finma.ch/en/documentation/finma-guidance/

Ausgabe von Immobilienfondsanteilen – Aktualisierung der FachinformationDie Praxis-Erfahrungen aus dem Kreise der Mit-glieder über die Jahre zeigten Bedarf einerseits nach vereinzelten Präzisierungen, anderseits nach Aktualisierung an aktuelle Gegebenheiten. Die am 21. Dezember 2018 aktualisierte Fach-information ist in den Sprachversionen deutsch und französisch auf unserer Website verfügbar. Die Fachinformation soll als Leitfaden bei der Pla-nung und Durchführung von Emissionen dienen und zu einer konsistenten Handhabung von Emis-sionen im schweizerischen Immobilienfondsmarkt beitragen.https://www.sfama.ch/de/selbstregulierung-musterdokumen-te/immobilienfonds-1

Federal Council wants to further improve framework conditions for blockchain/DLTDuring its meeting on 7 December 2018, the Fede-ral Council adopted a report on the legal framework for blockchain and distributed ledger technology (DLT) in the financial sector. The report shows that Switzerland’s legal framework is well suited to dea-ling with new technologies, including blockchain. Nevertheless, there is still a need for selective ad-justments. The Federal Council also noted the ana-lysis of an interdepartmental working group on the money laundering and terrorist financing risks po-sed by crypto assets.https://www.admin.ch/gov/en/start/documentation/media-re-leases.msg-id-73398.html

Daniela Stoffel appointed State Secretary for International Finance During its meeting on 16 January 2019, the Federal Council appointed Daniela Stoffel, Head of Political Staff at the State Secretariat for International Fi-nance (SIF) and Diplomatic Advisor to the Head of the Federal Department of Finance (FDF), as State Secretary for International Finance in the FDF. She succeeds State Secretary Jörg Gasser, who is lea-ving the Federal Administration at his own request at the end of February 2019 in order to pursue a change of career. Daniela Stoffel took up her post on 1 March 2019. https://www.admin.ch/gov/en/start/documentation/media-re-leases.msg-id-73684.html

Benjamin Gentsch elected to FINMA Board of Directors During its meeting on 30 January 2019, the Fede-ral Council elected the certified insurance specialist Benjamin Gentsch as a new member of the Board of Directors of the Swiss Financial Market Super-visory Authority FINMA. Mr. Gentsch will take up office on 1 July 2019. https://www.admin.ch/gov/en/start/documentation/media-re-leases.msg-id-73821.html

Überarbeitung der AIA-WegleitungDie Eidgenössische Steuerverwaltung (ESTV) hat am 23. Januar 2019 auf ihrer Website eine über-arbeitete Fassung der AIA-Wegleitung publiziert. Sie finden diese über den folgenden Link:https://www.estv.admin.ch/estv/de/home/internationales-steu-errecht/fachinformationen/aia/publikationen/wegleitung.html

Die Überarbeitung hatte insbesondere den Zweck, die «Klarstellungen zur Wegleitung», welche bisher als separate Fragen und Antworten auf der Website der ESTV publiziert waren, in die Wegleitung zu integrieren. Die Klarstellungen betreffen mitunter Trustee-documented Trusts, die Einordnung von Edelmetallen und Futures sowie die Definition von Finanzvermögen und Holding NFE. Die separaten Fragen und Antworten sind nach der Publikation der überarbeiteten Wegleitung auf der Website der ESTV nicht mehr abrufbar. Darüber hinaus wurden im Rahmen der Überarbeitung weitere punktuelle Ergänzungen und Präzisierungen vorgenommen, etwa um aktuelle Entwicklungen wie beispielswei-se die Aufhebung von Art. 1 AIAV (Whitelist) per 1. Januar 2019 einzubeziehen.

Praxisentwurf MWSTG KryptowährungenDie ESTV hat am 29. Januar 2019 einen überar-beiteten ersten Entwurf zur Mehrwertsteuer-Praxis zum Thema Krypto-Währungen auf ihrer Internet-seite aufgeschaltet. Die Frist zur Stellungnahme ist abgelaufen. Der erste Entwurf bleibt jedoch auch nach der Praxis-Konsultation aufgeschaltet. https://www.estv.admin.ch/estv/de/home/mehrwertsteuer/fach-informationen/publikationen/mwstg-ab-2010/entwuerfe.html

State Secretariat for International Finance The SFI Newsletter provides regular information on the latest news from the business areas covered by the State Secretariat for International Finance. It is published three to four times a year in German and French. http://www.sif.admin.ch Documentation

19SFAMA News Spring 2019

LIBOR replacementThe UK’s Financial Conduct Authority (FCA) has announced that it no longer intends to support the LIBOR benchmark interest rate from 2021 onward. Alternative reference rates are therefore currently being discussed around the world – including in Switzerland. The Swiss Financial Market Super-visory Authority FINMA has published guidance detailing the risks of a potential replacement of LI-BOR. https://www.finma.ch/en/news/2018/12/20181217-aktuell-li-bor-aufsichtsmitteilung/

EU-Organe einigen sich auf ESG-TransparenzregelnDie so genannten Trilog-Partner der EU haben sich darauf verständigt, wie Investoren und Finanzins-titute künftig die Berücksichtigung von Nachhaltig-keitskriterien transparent machen sollen. Mit einer endgültigen Verabschiedung der Verordnung ist al-lerdings nicht vor Ende 2019 zu rechnen.https://www.fondsprofessionell.de/news/recht/headline/eu-or-gane-einigen-sich-auf-esg-transparenzregeln-151504/

Disclosure of ESG matters by issuersThe International Organization of Securities Com-missions (IOSCO) has published a statement set-ting out the importance for issuers of considering the inclusion of environmental, social, and gover-nance (ESG) matters when disclosing information material to investors’ decisions.https://www.iosco.org/library/pubdocs/pdf/IOSCOPD619.pdf

EFAMA and AMIC publish joint report on liquidity stress tests in investment fundsEFAMA and the International Capital Market Asso-ciation’s Asset Management and Investors Coun-cil (ICMA’s AMIC) have published a joint report on liquidity stress testing (LST) in investment funds. The report highlights the role of stress tests as an important risk management tool allowing the fund manager to assess the impact of different market stresses at the portfolio level. Moreover, it outlines the long-standing standard practices in the fund industry and the existing comprehensive require-ments foreseen by European and national laws.https://www.efama.org/Pages/EFAMA-and-AMIC-publish-jo-int-report-on-liquidity-stress-tests-in-investment-funds.aspx

Pepp agreement provides pep to fund industry, says EFAMAFollowing approval by the European Parliament’s Economic and Monetary Affairs Committee (ECON) of the proposed pan-European Personal Pension Product (Pepp), the European Fund and Asset Management Association has said it is a welcome move that will encourage European citi-zens to save for retirement.https://www.investmenteurope.net/advice/4001116/pepp-ag-reement-provides-pep-fund-industry-efama

International Environment

Crypto-assets need common EU-wide approach to ensure investor protectionThe European Securities and Markets Authority (ESMA) published its Advice to the European Union Institutions on initial coin offerings and crypto- assets. The document clarifies the existing EU rules applicable to crypto-assets that qualify as financial instruments and provides ESMA’s position on any gaps and issues in the current EU finan-cial regulatory framework for consideration by EU policy makers.https://www.esma.europa.eu/press-news/esma-news/cryp-to-assets-need-common-eu-wide-approach-ensure-inves-tor-protection

Revised Guidelines on outsourcing arrangementsThe European Banking Authority (EBA) has publis-hed its revised Guidelines on outsourcing arrange-ments setting out specific provisions for the gover-nance frameworks of all financial institutions within the scope of the EBA’s mandate with regard to their outsourcing arrangements and related supervisory expectations and processes. The aim of the Guide-lines is to establish a more harmonized framework for these financial institutions, namely credit insti-tutions and investment firms subject to the Capital Requirements Directive, as well as payment and electronic money institutions. The recommendation on outsourcing to cloud service providers, publis-hed in December 2017, has also been integrated into the Guidelines.https://eba.europa.eu/-/eba-publishes-revised-guideli-nes-on-outsourcing-arrangements

21SFAMA News Spring 2019

Sfama Activities

MembersThe Board of Directors and the Executive Board were pleased to welcome the following member to SFAMA at the beginning of the year:• Reichmuth & Co Investment Management Inc.

Specialist committeesThe specialist committees essentially undertake the preparatory work for decisions relating to their specific areas, which they then submit to the Board of Directors and the Executive Board. The indivi-dual committees were/are actively involved with the following issues.

Alternative InvestmentsRégis Martin• Preparatory work for creating a new brochure

on alternative investments• Discussion of focus topics private equity and

private debt

ETFs & Indexed InvestmentsMarkus Götschi• Work on amending CISO in line with FinSA and

FinIA• Continuation of the discussion on the need to

list all unit classes in Switzerland

Real Estate FundsRoger Hennig• Revision and fine-tuning of the SFAMA spe-

cialist information factsheet on the issuance of real estate fund units based on experience gained with issues in recent years

• Radio and Television Act and real estate funds with direct property ownership

• FinSO/FinIO consultation

Processes & OperationsDaniel Lüdin• FinSO/FinIO consultation• Hard Brexit

Risk ManagementMartin Jufer• Discussion of risk management approaches at

individual institutions with a view to determining best practice

• Drafting a concept for a specialist risk manage-ment event

Legal & ComplianceDiana Imbach (ad interim)• Consultation on the revision of the Ordinance

on Investment Foundations• FinSO/FinIO consultation• Treatment of class actions in connection with

the liquidation of a fund• Materiality in the context of Section 4 § 19 of

the SFAMA model fund contract for a securities fund

Legal & Compliance Asset ManagementJasmin Djalali• Discussion of ESG aspects and their impact on

Switzerland• Sharing experiences with regard to the SFAMA

model loyalty declaration in accordance with OPO2

• Discussion on exchange equivalence • FinSO/FinIO consultation

TaxesHanspeter Kurz• Federal Act on Tax Reform and AHV Financing

(TRAF), reform of withholding tax, abolition of stamp duty

• FinSO/FinIO consultation• Double taxation agreements• Radio and Television Act in relation to real esta-

te funds with direct property ownership• Recommendations on reforming withholding tax

Distribution & MarketingMarkus Signer• Discussion of changes relating to “distribution”

with FinSA/FinIA due to the change of terms from “distribution” to “offering”.

• In-depth study on the subject of fund platforms• Twitter activities geared to current investment

fund topics

Upcoming events

GIPS Day 2019Tuesday, 22 October 2019Hotel Metropol, Zurich

Swiss Fund Day 2019Thursday, 21 November 2019Park Hyatt, Zurich

More detailed information on these events will be published on the Internet in due course.http://www.sfama.ch/en/events

23SFAMA News Spring 2019

Swiss Fund Data

Swiss Fund Data community still growingAccording to Google Analytics, around 33,000 users visit the platform every month, up from 28,000 in the first quarter of 2018 and 21,000 in the first quarter of 2017. Monthly page views have now risen above 250,000. The platform has thus succeeded in increasing its visitor numbers by around 58% in the space of two years, further strengthening its position as a high-quality source of information on funds.

Many new providers on www.swissfunddata.chThe following new providers have joined since the last SFAMA News was published:• Metzler Asset Management GmbH• Lazard Asset Management Schweiz AG• Crypto Fund Ltd• FIL Investment Switzerland Ltd.• Axxion S.A.• Fisch Asset Management AG• Baloise Asset Management• Eurizon Capital SA• Tabula Investment Management• Merian Global Investors (Switzerland) LLC• DNCA Finance• Quaero Capital SA• Foord Asset Management (Singapore) Pte. Limited• 2Xideas LTD

Thanks to these new members as well as the organic growth of existing members, the number of classes published on www.swissfunddata.ch rose by almost 7% in 2018 to more than 16,600. This impressive growth will enable Swiss Fund Data to offer additional services, some of which will be completely new to the Swiss fund market.

24SFAMA News Spring 2019

Use of event calendar free of chargeThe Friends of Funds forum is continuing to offer an independent calendar for fund and financial in-dustry events in Switzerland, intended for events of all kinds (including those with restricted audien-ces). If you have dates for roadshows, media con-ferences, seminars, anniversaries or other events, you can publish these free of charge via the www.friends-of-funds.ch website (under “Events / Ihre Veranstaltung”). http://www.friends-of-funds.ch/events/zürich/neue-veranstaltung-anmelden

Federal Council initiates consultation on partial revision of Banking Act During its meeting on 8 March 2019, the Federal Council initiated the consultation on the partial re-vision of the Banking Act (BA). It proposes revised rules on bank restructuring, strengthening deposit insurance, and supplementary provisions on the segregation of intermediated securities. The con-sultation will last until 14 June 2019. https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-74246.html

Annual GIPS standards notification form: deadline is 30 June 2019Firms that claim compliance with the Global Invest-ment Performance Standards (GIPS®) are requi-red to notify CFA Institute of their claim of com-pliance. There are different procedures depending on whether the firm is filing for the first time (New Claim of Compliance) or is filing an annual upda-te (Returning Firm). Firms that are newly claiming compliance must submit the GIPS compliance no-tification form prior to publicly claiming compliance. Once a firm claims compliance, its notification must be updated annually by 30 June of each year. The only required information is the name of the firm, contact details for a primary and secondary con-

Interesting Reading

Friends of FundsSFAMA has a long-standing partnership with the neutral discussion forum Friends of Funds. The dates and topics set thus far are as follows:

Events in Zurich (cycle 32):19.03.19 Fundtech – the next challenge for asset

management09.04.19 The fund business over the past 20 ye-

ars 21.05.19 Alternative investments and Absolute

Return 2.025.06.19 Legal update: What lies in store?

Events in Geneva (cycle 13)04.06.19 Topic to be defined 10.09.19 Topic to be defined03.12.19 Topic to be defined

Further information on the events in Zurich and Ge-neva, where available, can be found on the forum’s website at www.friends-of-funds.ch

New sectionsThe website was revamped at the beginning of 2016, and various new features added. Visitors have since been able to download documents such as studies, research reports, PowerPoint presen-tations, and survey results of partner companies. These can be found in the sections “Investment Center”, “Service Center”, “Education Center”, and “News Center”.

25SFAMA News Spring 2019

EFAMA welcomes sustainability rules but warns on timeframeEU countries will not have long enough to incor-porate sustainability rules into their investment fund regulation, the asset management industry has warned Brussels.

The European Securities and Markets Authority (ESMA) is consulting on integrating sustainabili-ty risks and factors into the EU’s fund directives (Undertakings for Collective Investment in Trans-ferable Securities (UCITS) Directive and Alternati-ve Investment Fund Managers Directive (AIFMD)) and into the Markets in Financial Instruments Di-rective (MiFID II).http://www.funds-europe.com/news/efama-welcomes-sus-tainability-rules-but-warns-on-timeframeLink to EFAMA statements:https://www.efama.org/Publications/Public/AIFMD/19-4018.pdfhttps://www.efama.org/Publications/Public/MiFID-Mi-FIR/19-4009.pdf

Update of the Country Sustainability RankingThe Autumn Update of RobecoSAM’s Country Sustainability Ranking shows that the Scandina-vian countries and Switzerland have consolidated their leading positions, while the emerging giants India and China remained among the weakest ESG performers. They are also ranked at the bot-tom of RobecoSAM’s investment universe.https://www.robecosam.com/media/9/7/2/97240b9afc893d103d558ce50f066bc5_2018-11-robecosam-country-sustainability-ranking-en_tcm1011-16188.pdf

Inspiring Investment Partnerships to Achieve Global GoalsIn this new publication, SSF takes stock of key lessons on the role of private- and public-sector actors in creating successful investment part-nerships to attract necessary capital and achieve global goals. Concrete case studies based on the experience of SSF members illustrate how such investment partnerships can be put into practice.http://www.sustainablefinance.ch/en/ssf-publications-_content---1--3037.html

tact, and information on whether the firm has been verified within the past 24 months. Other questions, including total firm assets, are optional. All informa-tion provided must be correct as at 31 December the previous year.

Firms filing a New Claim of Compliance should use the New Claim of Compliance link; returning firms should use the Returning Firm link.

FINMA guidelines on conducting the regulatory auditThe Swiss Financial Market Supervisory Authority FINMA has updated its guidelines for audit firms of institutions licensed under the Collective Invest-ment Schemes Act on conducting the regulatory audit.https://www.finma.ch/en/supervision/cross-sector-issues/audi-ting/auditing-of-banks/

Introducing a comprehensive cost indicator for fundsMorningstar has introduced a new cost indicator that takes account of the requirements of the EU’s Markets in Financial Instruments Directive (MiFID) while also addressing the shortcomings of existing cost indicators. The “representative cost” data point covers recurring fees, performance fees, and trans-action costs. h t t p : / / w w w . m o r n i n g s t a r . d e / d e / n e w s / 1 8 1 4 7 3 /auf-dem-weg-zu-einer-umfassenden-kostenkennzi f -fer-für-fonds.aspx

Coredataresearch: Five Key Challenges Facing Asset Managers in 2019The asset management industry stands at a criti-cal juncture at the start of 2019. Unprecedented geopolitical and macroeconomic uncertainties, the return of volatility, and industry-specific challenges throw up a host of dangers for the sector. Asset ma-nagers will compete in a survival of the fittest con-test played out in a hostile investment ecosystem. The winners will be those that can overcome – and exploit – the most pressing challenges.https://coredataresearch.co.uk/blog/five-key-challenges-fa-cing-asset-managers-in-2019/

26SFAMA News Spring 2019

SKSF Jahresbericht 2018Die Schweizerische Kommission für Standardi-sierungen im Finanzbereich (SKSF) hat im Jahr 2018 in ihrer zentralen Rolle für die Standardisie-rungsarbeit viel erreicht. Der SKSF-Jahresbericht 2018 bietet einen komprimierten Überblick über die wichtigsten Ereignisse der Kommission und die Arbeit, welche die Experten für den Finanz-platz Schweiz und Liechtenstein geleistet haben. http://sksf.ch/images/Gesch%C3%A4ftsleitung/Jahresbe-richt/SKSF_GB_2018.pdf

BVI veröffentlicht neue Broschüre für VermittlerDer Fondsverband BVI hat eine überarbeitete Broschüre mit Informationen zur Anlage in Fonds und deren Vorteile bei der Altersvorsorge veröf-fentlicht. Das Dokument richtet sich an Vermittler und ist für den Einsatz im Kundengespräch ge-dacht. Die Broschüre mit dem Titel «Langfristig Vermögen aufbauen – mit Fonds für das Alter vorsorgen» kann kostenlos heruntergeladen oder beim BVI bestellt werden.https://www.bvi.de/bvi/publikationen/

Report on Pension Funds Statistics and Trends 2018PensionsEurope has published its annual statistics and Report on Pension Funds Statistics and Trends 2018. Tightening monetary policy is attracting more money to bond investments, and this applies for pension funds as well. However, many pension funds have indicated that they do not expect sig-nificant changes to their investments in sovereign bonds, and in some countries these investments are even expected to continue to decline in spite of rising interest rates.https://www.pensionseurope.eu/pensionseurope-report-pensi-on-funds-statistics-and-trends-2018

Wo die Gelder unserer beruflichen Vorsorge steckenImmer mehr inländischer Beton, immer mehr aus-ländische Wertpapiere: die Anlagen der schweize-rischen Pensions¬kassen im Zeitvergleich. In der beruflichen Vorsorge der Schweiz hat sich einiges getan. Die Gelder, die in der zweiten Säule ange-legt sind, haben sich in den dreizehn Jahren nahe-zu verdoppelt: von 484 Mrd. CHF im Jahr 2004 auf 894 Mrd. CHF im Jahr 2017.https://www.republik.ch/2019/02/11/wo-unsere-beruflichen-vorsorgegelder-stecken

27SFAMA News Spring 2019

Editorial teamSwiss Funds & Asset Management Association SFAMAP.O. Box, CH - 4002 BaselPhone +41 61 278 98 00office@sfama.chwww.sfama.ch

Layout and implementationR Consult LLCMarkus RöthlisbergerP.O. Box 24, CH - 5022 RombachPhone +41 62 827 37 47roethlisberger@r-consult.ch

Author‘s opinions Quoted articles or links to corresponding sources do not necessarily coincide with the views of the SFAMA.

LiabilityThe SFAMA accepts no liability whatsoever for the correctness of the text and fi gures stated in this publica-tion, in particular for contributions from third-party sources. The present English version is a translation of the original document in German

Copyright The reprinting and reproduction of the content of this publication (including excerpts) are permitted provided the original source is acknowledged.

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The SFAMA News is published 4 times a year (in March, June, September, and December) in English, German and French. The download facility and subscription form can be found on the SFAMA website at

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