“Commercial basis” = accepting funds from more than 20 depositors or publicly advertising as doing so (even if results in fewer than 20 depositors)
Sandbox Exemption
Banking license not required if the following requirements are met (even if over 20 depositors):
- maximum CHF 1 million
- not operate interest rate differential business
- investing and paying interest on received deposits is allowed
- inform depositor before the deposit that:
- institution is not supervised by FINMA; and
- deposit is not covered by deposit guarantee
