Don’t Blame the Wrapper

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  Susan Niederhöfer
  Chefredakteurin

Mr Wagner, you have been observing the AMC market for years. FINMA’s Supervisory Communication 03/2026 confirms that rapid growth has not been accompanied everywhere by the necessary diligence. Did that come as a surprise to you, or more of an overdue wake-up call for the industry?

The supervisory communication confirms a development I have been observing for some time: a very small minority of AMC issuers and asset managers push the boundaries of what is possible, while the overwhelming majority operate responsibly. In my view, FINMA is not criticising the instrument, but the lack of professionalism in transparency, governance and decision-making processes.

FINMA names five specific risk patterns: inadequate suitability assessment and consideration of risk capacity or risk tolerance, non-transparent double fees, conflicts of interest when using in-house products, deficient risk management, and control gaps in due diligence and compliance. You say: “Don’t blame the wrapper.” Why are, in your opinion, these five shortcomings a problem which is down to people and processes rather than a problem of the product itself?

None of the five findings is a characteristic of an AMC. Suitability assessment, fees, conflicts of interest, risk management and compliance are tasks of the provider – regardless of whether it is an AMC, a fund or a portfolio management mandate. The five points are not AMC issues; they are basic principles of professional asset management.

FINMA’s wish list reads like a spec sheet for a modern AMC platform: suitability assessment is documented, fees are disclosed transparently, due diligence is traceable, and control functions are clearly assigned. But which of these five points can be fully automated today, and which ones remain a human responsibility?

Technology doesn’t replace responsibility. It ensures that decisions are documented, traceable and implemented in compliance with the rules. Humans decide – the platform makes that decision verifiable.

vestr invests a lot of time in AMC education. There are whitepapers, masterclasses and trainings programmes for asset managers and investors. What questions do informed investors ask that uninformed investors do not, and what would have happened if more market participants had asked these questions earlier?

Where does the money actually flow? What is the actual flow of funds after subscription? How is that money protected? Who holds it, who controls it, and are the protection mechanisms robust? How are the returns protected? Who ensures that returns are not misappropriated? What does the exit strategy look like? Is there a functioning secondary market, or are you locked into the product until maturity?

As an investor, what would be the first question you would ask?

How is the invested capital protected? Who holds the assets, and what safeguards are in place? Since most AMCs are structured as debt securities, investors carries the credit risk of the issuer. For this reason, it is essential to carefully assess who the issuer is and which protection mechanisms are available.

You say that “active” can have three completely different meanings in the AMC context, and that artificial intelligence is increasingly making the distinction between active and passive management redundant. Can you elaborate?

I think that today the terms “active” and “passive” confuse more than they help. Even “active” can have three different meanings in the AMC context:

• Portfolio management: the portfolio is managed discretionarily by a portfolio manager.
• Underlyings: the underlyings are liquid and actively traded.
• Product: the product itself is tradable.

These three meanings have little to do with one another. That’s why investors should always ask: does “active” refer to portfolio management, the liquidity of the underlyings, or the tradability of the product?

The classic distinction between active and passive is also becoming increasingly blurred. It still exists from a regulatory standpoint. For investors, however, other questions matter more: is the strategy transparent? Who is responsible for the outcome? And are investment decisions based on human judgement or on a model that can’t be fully explained?

Artificial intelligence makes this development particularly clear. An AI model can deviate strongly from the benchmark and, thus, appear active. At the same time, it makes its decisions without human judgement and, thus, appears passive. In fact, it fits into neither category. That’s why I believe we will in future talk less about “active” versus “passive” and more about transparency, accountability and traceability.

FINMA criticises in its supervisory communication that, in particular, smaller institutions often outsource their compliance functions to unlicensed external service providers, whose responsibilities are sometimes unclear. How should this problem be addressed? Should in-house capacity be increased, the quality of external service providers be improved, or a platform be created that can take on this function structurally?

I think the question isn’t in-house versus outsourcing. The real question is: who ultimately carries the responsibility? Quality doesn’t depend on the size of an organisation, but on clear accountability. External specialists can be just as appropriate as internal teams. What matters is that it is always clear who decides, who controls, and who is accountable. Responsibility can be delegated, but not given away. Modern platforms replace neither compliance nor governance. They ensure that processes run in a standardised, transparent and audit-proof way.

The Swiss AMC market has developed into an international role model. With a total market of CHF 235 billion, AMCs remain one of the fastest-growing segments. Why shouldn’t the industry see the current development as an opportunity for professionalisation rather than a reason to question the instrument?

I see FINMA’s supervisory communication as a sign that the AMC market has come of age. Every successful financial market product goes through three phases: innovation, growth and professionalisation. Whoever invests in better processes, more transparency and modern technology builds trust with investors and regulators. That’s exactly how successful markets continue to evolve.

If an asset or wealth manager were to start today with AMC infrastructure, what three non-negotiable requirements should they set for their platform?

Firstly: the net asset value (NAV) must be correct. If the valuation is wrong, nothing else matters. A correct NAV isn’t a differentiator; it’s the minimum requirement.

Secondly: compliance must be anchored in the workflow. Pre- and post-trade controls, limits, approvals and documentation must not take place at a later stage, but must be an integral part of the process.

Thirdly: transparency and a complete audit trail are essential. Every decision and every change must be traceable at all times.

If any of these three building blocks is missing, it doesn’t matter how modern a platform looks.

FINMA documents this by means of an annual data collection that includes an AMC section, escalation cases and supervisory communications. For whom is this a challenge, and for whom an opportunity?

I think it is both: a challenge for everyone who has to live with manual processes and a lack of transparency. But it’s also an opportunity for everyone who relies on clean processes, clear accountability and transparency. Those who work professionally have nothing to fear from closer supervision – on the contrary, it makes quality visible.

Thank you very much for the conversation, Mr Wagner!

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Stefan Wagner
Head of Business Development at vestr

Stefan Wagner has more than 30 years of experience in capital markets, Structured Products and fintech. His career took him from Bankers Trust via Salomon Brothers, Citigroup and Vontobel to vestr AG, where he now heads Sales, Marketing and Customer Success as Head of Business Development. He is also a member of the investment committees of Fortem Capital and Falco Private Office, and founder and host of the Nalu Finance Podcast. He is one of the few market participants who knows the AMC business from the perspective of issuers, asset managers, infrastructure providers and investors alike.