By mid-April FINMA had received 95 of the some 2,500 licence applications that it expects to receive by the end of 2022 and had licensed the first 36 portfolio managers. Based on these initial experiences with the licensing process, FINMA set out its expectations of itself, the applicants and the supervisory organisations. Furthermore, FINMA provided information about the risk-based licensing approach and its interpretation of the term “high-risk business model”.