Interpretations of the Normative Framework - Annual Administration Fee (AAF) 

FSC has published the following interpretations, which are available in this document (relevant page numbers mentioned below):

• On page 07, INT-POL-20-005_09 (amended) clarifies options beyond OANDA for currency converters with examples.
• On page 09, INT-POL-20-005_20 (new) clarifying the use of 100,000 USD FPT figures for group members that have not yet completed the fiscal year.
• On page 10, INT-POL-20-005_13 (amended) providing the non-conformity and exception pathways, which were added/clarified in the flowchart.
• On page 11, INT-POL-20-005_15 (amended) clarifying the data entry requirements for non-conformity and exception pathways.
• On page 13, INT-POL-20-005_21 (new) clarifying the time zone to calculate Annual Administration Fee (AAF) on the determination date of each quarter as per Annex 3, Table 3.

The tracked changes version of the interpretation is attached for your reference. For questions please contact us at aafsupport@fsc.org.