Trustees

Anyone who acts as a trustee on a commercial basis must be licensed by SFMA. This requires trustees to meet various financial, personnel-related and organisational requirements.

This SFMA page gives applicants and supervised institutions a practical view of the trustees topic. It explains when a licence, approval, notification or registration may be needed, what information should be prepared, and which changes may require contact with the authority.

Licensing requirements

The review focuses on whether the applicant is organised in a way that is suitable for trustees within the Portfolio managers and trustees area. SFMA will normally look at governance, financial resources, responsible persons, risk controls, compliance arrangements, auditability, outsourcing and whether the planned activity can be carried out without creating avoidable risks for clients, investors, policyholders or market integrity.

Date of licensing

Commercial nature of activity

This section explains how commercial nature of activity affects the trustees authorisation or registration topic. The relevant facts should be documented in a way that allows SFMA to understand the legal basis, operating responsibilities and supervisory implications.

Role

The practical role of trustees should be described clearly in the application file. This includes the services performed, the counterparties involved, the assets or products affected, decision-making responsibilities and the way records, reporting and controls are maintained after authorisation.

Cessation of the activity requiring a licence

Material changes should be assessed before implementation. Changes in ownership, management, organisation, business activity, documents, outsourcing, risk models or the decision to stop a licensed activity can require prior approval or notification. Applicants and licence holders should keep the authorisation basis aligned with their actual operating model.

Submitting applications

Applications should be submitted with the current forms, declarations and supporting documents required for the activity. A complete file usually shortens the review because the authority can assess the business model, responsible persons, financial position, internal rules and legal basis without repeated follow-up questions.

Preparing a complete file

Applicants should keep the submission concise but complete: describe the activity, legal structure, people responsible, control framework, financial resources, relevant documents and any cross-border elements. Where uncertainty remains, the issue should be highlighted early rather than left to emerge during review.