“Commercial basis” = accepting funds from more than 20 depositors or publicly advertising as doing so (even if this 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 deposits
- not operating interest rate differential business
- investing and paying interest on received deposits is allowed
- informing depositor before the deposit that:
- institution is not supervised by FINMA; and
- deposit is not covered by deposit guarantee
