Under the revised Federal Act on Data Protection, in a case where customer data is going to be transferred to a country that does not provide an appropriate level of data protection from a Swiss law perspective and where protection is ensured by using contractual clauses that are approved, issued or recognized by the Swiss Data Protection and Information Commissioner ("FDPIC"), notification to the FDPIC is no longer necessary for the transfer of data to other countries.

There is generally no need to inform or notify the Swiss Financial Market Supervisory Authority ("FINMA") in advance of any contemplated outsourcing. However, in exceptional circumstances, informing the FINMA may be required given the general obligation of a regulated entity to report any issues of substantial importance to the FINMA's supervision.