Where a digital advisory platform relies on the paragraph 11A reduced fact-find in FAA-N16, the recommendations it makes must be limited to:
Paragraph 11A permits the reduced fact-find only where, among other conditions, the recommendation is confined to collective investment schemes meeting the prescribed investment restrictions — broadly, CIS that qualify as Excluded Investment Products. It cannot be used for OTC derivatives, single stocks, or complex ILPs.
The carve-out is tied to simpler CIS (EIP-qualifying) — it does not open the door to derivatives, single equities or complex products.
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