Excellent point, it has to be best practice and yes a very big number of banks and asset managers are far away to have this under control. Above all this needs to be monitored regularly and not every few month only. Thats a must based on best practice but above all because it will be required in Switzerland from 2018, retroactively. An example for smaller and medium sized bank who are doing this already is Banque Piguet http://www.finews.ch/news/english-corner/23075-piguet-galland-links-up-with-performance-analyst and also Banque Gonet.
Perfect Swiss style approach. Smaller private banks innovating by adapting technologies that offer better service to their exisitng clients (with no extra fees)! Quality differentiation, attention to detail and service, is how the Swiss developed their industries (watches, machines, food etc).