FinSA Client information

Based on the legal requirements of Art. 8ff. of the Financial Services Act (FINSA), the sections below provide an overview of Alpen Partners AG (hereinafter referred to as the «financial institution») and its services.

 

Company information

Address

Alpen Partners AG
Wolleraustrasse 31
8807 Freienbach
Switzerland

+ 41 58 105 75 00
info@alpenpartners.com

The financial institution was established in 2008.

Supervisory authority and audit firm

At present, the financial institution is supervised by the self-regulatory organization FINcontrol c/o VQF Financial Services Standards Association (Financial Services Standards Association). With the new Financial Institutions Act (FinIA), all financial institutions will in the future need a license from FINMA to carry out their professional activities as a portfolio manager according to FinIA Art. 17. The deadline for submitting the application was the end of 2022. The financial institution submitted the application to the competent licensing authorities for authorization as a portfolio manager in June 2022. The future authorization status can be found on the homepage.

The financial institution is audited and reviewed by the auditing company AML Revisions AG both in terms of supervisory law and in terms of obligations. The address of the FINcontrol AG and ALM Revisions AG can be found below.


FINcontrol Suisse AG
c/o VQF Financial Services Standards Association
General-Guisan-Strasse 6
6300 Zug
Switzerland

+41 41 763 28 20
info@fincontrol.ch
www.fincontrol.ch

 

AML Revisions AG
Hohlstrasse 560
8048 Zürich
Switzerland

+41 44 533 82 00
zuerich@aml-revision.ch
www.aml-revision.ch

 

Ombudsman

The financial institution is affiliated with the independent ombudsman OFS (Ombud Finance Switzerland), which is recognized by the Federal Department of Finance. Disputes concerning legal claims between the client and the financial services provider should be settled by an ombudsman's office, if possible, within the framework of a mediation procedure. The address of the ombudsman’s office is stated below.

 

OFS Ombud Finance Switzerland
16 Boulevard des Tranchées
1206 Geneva
Switzerland

+41 22 808 04 51
contact@ombudfinance.ch
www.ombudfinance.ch

 

 

Information on the offered financial services

The financial institution provides investment advisory and portfolio management services.

In the case of a transaction-based investment advisory mandate with the financial institution, a recommendation relating to individual financial instruments is provided to the client. The decision to buy or sell remains always ultimately with the client.

The financial institution does not guarantee any yield nor performance of investment activities. The investment activity can therefore lead to an appreciation or a depreciation in value.

 

Client segmentation

Financial service providers are required to classify their clients into a client segmentation according to the law and adhere to the respective code-of-conduct. The Financial Services Act provides for «retail clients», «professional clients» and «institutional clients» segments. For each client, a client classification is determined within the framework of the cooperation with the financial institution. Subject to certain conditions, the client may change the client classification by opting out. The financial institution does not serve retail clients, only professional and institutional clients.

 

Information on risks and costs

General risks associated with financial instruments transactions

The investment advisory and portfolio management services involve financial risks. The brochure «Risks associated with Financial Instruments Transactions» can be found at www.swissbanking.org.

 

Clients of the financial institution may contact their relationship manager at any time if they have any further questions.

 

Risks associated with the offered services

For a description of the various risks that may arise from the investment strategy for clients’ assets, please refer to the relevant Non-Discretionary Investment Advisory Agreement or Discretionary Asset Management Agreement.

If unusual concentrations of risk within the client portfolio cannot be ruled out, the nature and extent of
such concentration risks shall be disclosed to the client. Indicators of such unusual concentrations of risk
are:

  • a concentration of 10% or more in individual securities.
  • a concentration of 20% or more in individual issuers.

Concentrations from collective investment schemes that are subject to regulatory risk diversification rules, such as UCITS funds and Swiss securities funds, are excluded.

 

Information on costs

A fee is charged for the services rendered, which is usually calculated on the assets under management and/or on a performance basis. For more detailed information, please refer to the relevant investment Non-Discretionary Investment Advisory Agreement or Discretionary Asset Management Agreement.

If it is not possible to determine the actual amount of remuneration or third-party services before the financial service is provided or the contract is concluded, the financial institution shall inform the client of the range of the respective remunerations, taking into account the different asset classes and financial instruments.

In the case of asset management and portfolio-based investment advice, if the exact amount of thirdparty remuneration cannot be determined in advance, the client shall be informed of the range of the expected remuneration in relation to the portfolio value and the agreed investment strategy.

 

Information about relationships with third parties

In connection with the financial services offered by the financial institution, economic ties may exist with third parties. The acceptance of payments from third parties as well as their treatment are regulated in detail and comprehensively in the respective Non-Discretionary Investment Advisory Agreement or Discretionary Asset Management Agreement.

 

Information on the market offer considered

The financial institution basically follows an «open universe approach» and tries to make the best possible choice for the client when selecting financial instruments.

If the financial institution offers both its own and third-party financial instruments in its market offering, it shall take appropriate organisational measures, such as implementing a procedure for selecting financial instruments based on objective criteria customary in the industry. If the possibility of customers being disadvantaged cannot be excluded, the financial institution shall disclose this to its customers.

 

Appropriateness and suitability

Appropriateness test for transaction-based investment advice

In the case of transaction-based investment advice, the financial institution provides investment advice for individual transactions without taking into account the entire client portfolio.

In this case, the financial institution must ascertain the client's knowledge and experience before recommending financial instruments. In addition, before recommending financial instruments, it must be determined whether they are appropriate for the client.

In particular, the company must ensure that it is aware of the client's knowledge and experience in relation to each relevant investment category used in the financial service.

Suitability test for portfolio-based investment advice and asset management

When providing portfolio-based investment advice, the financial institution provides investment advice that considers the client portfolio. When providing asset management services, the financial institution must also consider the entirety of the client portfolio it manages. In contrast to investment advice, it also makes the investment decision itself.

In both these cases, the financial institution must determine the financial circumstances and investment objectives as well as the knowledge and experience of the clients. In this context, the knowledge and experience relate to the financial service and not to the individual transactions.

The information gathered by the financial institution about the knowledge and experience of the clients must take account of the investment strategy, and the granularity of the survey must be adapted to the complexity and risk profile of the investment and the investment strategy. In particular, the financial institution must be certain about the knowledge and experience of the clients in relation to each relevant investment category used in the financial service. 

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