FIDLEG-Verhaltenspflichten: Umsetzungsfragen und Weiterentwicklung nach der initialen Umsetzungsphase

Since the transitional period of the Financial Services Act (FinSA) expired on 31 December 2021, financial service providers have gained more than two years of experience with the new, cross-sectoral regulation. In practice, as well as through the first audits that have now taken place, it has become clear that many fundamental (interpretation) questions relating to the conduct duties of the FinSA have not been conclusively clarified yet. The aim of this article is therefore to discuss selected implementation and interpretation issues and to demonstrate possible solutions for the implementation in practice.