FINMA is also responsible for supervising financial market infrastructures. However, the Financial Market Infrastructure Act (FMIA) states that systemically important financial market infrastructures are also subject to monitoring by the Swiss National Bank (SNB). In order to avoid overlaps in supervisory practice, FINMA and the SNB have defined their respective roles. On the one hand, the two authorities will exchange information and views, while on the other, key audit documents (risk analysis, audit strategy and reporting) will have to be provided simultaneously to both the SNB and FINMA. This will give both authorities access to equivalent information, enabling appropriate supervision and monitoring.
A standard audit strategy is applied for supervised institutions in FINMA Supervisory Categories 3 to 5. Here, the frequency and depth of the audit to be performed are determined by the net risk exposure in the audit fields. For supervised institutions in FINMA Supervisory Categories 1 and 2, FINMA exercises greater influence on the audit fields to be assessed by defining the audit strategy in a dialogue with the audit firm. For systemically important financial market infrastructures, the risk analysis and audit strategy are determined in agreement between FINMA and the SNB.
Once an audit firm has completed a regulatory audit of a financial market infrastructure, it communicates the findings to FINMA in the form of a standardised report. Where the infrastructure in question is systemically important, the results are also shared with the SNB. The report contains information about the conduct of the audit, a declaration of independence on the part of the audit firm, and further information about the business activities and organisation of the audited institution. It also contains the audit firm’s opinion on all irregularities which have been identified or on recommendations for improvements.
In exceptional circumstances, FINMA can appoint an audit mandatary. Potential candidates for this role are approved audit firms and independent third parties with relevant experience and specialist knowledge.