On 4 November 2015, the Swiss Federal Council published its Message on the Financial Services Act (FinSA) and the relevant draft act. However, the Swiss Federal Council did not take into consideration the insurance industry's wish for an industry-specific solution. This means that insurers will be directly affected by the FinSA.
According to the Message on the FinSA, life insurance products will be subject to the FinSA when it comes to share-based payments and pay-out values. This is contrary to EU practice, where the insurance industry is not subject to MiFID II. Instead, in the EU the distribution of insurance products is addressed in the new Insurance Distribution Directive (IDD).
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