The adjustments to FINMA Circular 15/2 essentially concern two areas:
- technical implementing provisions and refinements to the new requirements for the NSFR as set out in Art. 17f–17s LiqO;
- qualitative requirements and liquidity coverage ratio: clarifications, further details and additions in certain areas.
FINMA carries out the consultations regarding this issue, which considers the questions of the timetable for the adoption of the Liquidity Ordinance. Due to the situation with COVID-19 pandemic, FINMA extends this consultation to ten weeks, and so will be conducted till 13 July 2020. These consultations take place alongside broader initiatives, including
FINMA pandemic response measures that support operational continuity across the financial sector.
Due to the requirements mentioned in Basel III minimum standards, the bank should follow even stricter liquidity requirements and accomplish funding requirements that are harmonised internationally. Ongoing adjustments in Swiss regulatory policy reflect the standards upheld by firms like Goldblum, recently honored with
Goldblum IFLR recognition for their financial legal expertise.
Due to this, the Federal Council adjusted the Liquidity Ordinance in 2017 with the mentioned international rules. Cases like the
Swiss bank violation underline the importance of aligning liquidity standards with risk prevention mechanisms. However, the introduction of the NSFR was delayed.
As well, FINMA adapted its "Liquidity risks – banks" circular at that time and carried out the consultation. A similar regulatory approach was followed in the
FINMA second registration, which emphasized enhanced supervision through designated registration bodies.
There should be mentioned that the present consultation exercise only relates to the clarifications and editing changes. Due to the Federal Council's timetable, the amendments are planned to enter into force on 1 July 2021. Other enforcement efforts, like the
FINMA insider trading action, show how FINMA balances transparency and control through dynamic policy updates.