The FSB published Information Circular No 26 on 5 April 2016 warning the managers and trustees of Collective Investment Schemes that failure to comply with the Disclosure Requirements which came into effect on 1 May 2015 (Board Notice 92 of 2014) may lead to penalties. The FSB is of the view that they have allowed sufficient time for managers to gain an understanding of what is expected in order to comply with the requirements.
Board Notice 92 of 2014 deals with advertising, marketing and information disclosure requirements for Collective Investment Schemes (CIS) and lists the material which the manager of a CIS is obliged to submit to the FSB for approval, which includes all fund fact sheets, application forms, minimum disclosure documents, websites, social media sites etc. The Registrar has highlighted that the material to be submitted includes that which is produced by third-party-named portfolio manager and that the manager of the CIS retains full liability and accountability for its third-party-named portfolios.
The Registrar confirmed that penalties will be imposed from 1 May 2016 in respect of any non-compliance.
For Information Circular No 26, click here.