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Types of Collective Investment Schemes & Their Restrictions *(Part I)*

Concept

The Code on Collective Investment Schemes sets baseline investment and borrowing limits, then layers extra rules on specialised fund types via dedicated appendices. Knowing what each fund is, who it suits, and where its restrictions differ from the standard limits is what separates a suitable recommendation from an unsuitable one.

Key rules & facts

  • Money-market funds — invest in short-term deposits and high-quality debt; aim for capital preservation. Subject to weighted-average-maturity and credit-quality caps (verify: WAM ≤ ~12 months).
  • Index funds / ETFs — passively track a benchmark; low cost. Synthetic/swap-based ETFs carry counterparty exposure (general single-counterparty derivative limit ~10% — verify).
  • Property funds / REITs — hold real estate; income-oriented but less liquid. Governed by a separate Property Funds Appendix with a higher leverage cap (verify: ~45–50% of deposited property), development limits, and a minimum-distribution requirement for tax transparency.
  • Hedge funds — use leverage, short-selling and derivatives; higher risk; usually offered as restricted schemes to accredited/institutional investors.
  • Fund-of-funds — invest in other CIS; limits on single-underlying-fund exposure and rules against excessive fee layering.
  • Capital-guaranteed vs capital-protected — *guaranteed* requires an eligible guarantor standing behind it; *protected* relies on the structure/instruments, not a promise. This is a key disclosure distinction.
  • General Code limits: ~10% of NAV per single issuer; borrowing ~10% of NAV (temporary only); spread-of-investment/diversification; and liquidity/permissibility requirements. (verify thresholds.)

Key data — CIS types, suitability & key restriction

Fund typeSuits (need)Key restriction vs standard
Money-marketCapital preservation, parking cashWAM & credit-quality caps (verify: WAM ≤ ~12m)
Index fund / ETFLow-cost market exposureSynthetic ETF counterparty limit (~10%, verify)
Property fund / REITIncome, real-estate exposureHigher leverage cap ~45–50% (verify); own appendix
Hedge fundSophisticated, higher-risk returnRestricted scheme; accredited/institutional only
Fund-of-fundsDiversification via other CISSingle-underlying-fund limit; no fee layering

Capital-guaranteed vs capital-protected

Capital-guaranteedCapital-protected
Basis of protectionAn eligible guarantorProduct structure/instruments
Is capital promised?Yes, by the guarantorNo hard promise — depends on structure
Key disclosure pointIdentity/creditworthiness of guarantorProtection is conditional, not guaranteed

Worked example

A client asks whether a REIT's borrowing is capped at the standard ~10% of NAV. It is not — property funds fall under the Property Funds Appendix, which permits a much higher leverage cap (verify: ~45–50% of deposited property). Assuming the general limit applies would be wrong.

Exam angle

Situational — a client profile → "which fund is most suitable?" or "which restriction applies to a property fund but not a money-market fund?"

⚠ The trap

Treating capital-guaranteed and capital-protected as synonyms; and assuming REIT/property-fund borrowing limits equal the standard ~10% (they have their own higher cap).

Takeaway

Match the fund to the client's need, then check whether a special Code appendix (property/hedge/fund-of-funds) overrides the standard limits.

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