Supervisory organisations

Supervisory organisations oversee licensed portfolio managers and trustees. They are authorised and supervised by SFMA and form an important part of the supervisory architecture.

A supervisory organisation must be independent, properly governed and capable of monitoring the institutions affiliated with it. It needs clear rules, competent staff, reliable processes and escalation procedures for cases where supervised firms do not meet their obligations.

Authorisation and supervision of SOs

To obtain authorisation, an applicant must explain its organisation, ownership, governance, financial resources, supervisory methodology, audit approach, reporting process and conflict management. SFMA checks whether the organisation can carry out supervision consistently and whether its rules reflect the legal requirements for portfolio managers and trustees.

Once authorised, a supervisory organisation remains subject to SFMA oversight. It must report relevant developments, maintain its capacity, apply its rules consistently and ensure that supervised firms are assessed with appropriate depth.

The organisation should have a risk-based approach that determines how frequently and intensively affiliated firms are reviewed. Its procedures should cover onboarding, periodic monitoring, incident handling, remediation deadlines, sanctions and the point at which a matter must be escalated to SFMA.

Changing supervisory organisation

Portfolio managers and trustees may need to change supervisory organisation, for example when a business relationship ends or a firm reorganises. Such changes must be planned carefully so that there is no gap in supervision. The firm must ensure that its authorisation basis remains valid and that SFMA and the organisations involved receive the necessary information.

The outgoing and incoming organisations should coordinate the transfer of relevant supervisory information. The supervised firm remains responsible for maintaining continuous affiliation and for explaining any unresolved findings or open remediation measures.

Public information

Information on authorised portfolio managers and trustees helps clients and counterparties check whether a provider is licensed. Public registers and search tools should be used together with direct due diligence and contractual review.

Public lists and forms

The authority publishes lists of authorised supervisory organisations in spreadsheet and PDF form. These lists make it possible to verify whether an organisation is authorised to supervise portfolio managers and trustees. The source page also provides forms for changes concerning responsible persons and declarations on pending proceedings, qualified participations and other mandates.

Those declarations support the fit and proper assessment of the people and owners connected with a supervisory organisation. They help the authority identify conflicts, control issues or circumstances that may affect independent supervision.

Supervision model

A supervisory organisation must have a methodology for monitoring affiliated firms. This includes risk classification, review cycles, reporting, escalation, sanctions and follow-up of remediation. The organisation should be able to show how it applies its rules consistently and how it keeps sufficient staff and expertise for the number and type of firms it supervises.

Because supervisory organisations are themselves authorised and supervised, they must notify relevant changes and maintain their own governance. If their resources, rules, responsible persons or ownership change, they should consider whether the authority must be informed or asked for approval.