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We have published a guide to provide background information on how we work with operators regarding non-mainstream pooled investments (NMPI). For operators of products that do not fall within this definition, we expect that certain thresholds are met regarding the appropriateness of the investment for all our customers.
A NMPI means: investments or ‘funds’ characterised by unusual, speculative or complex assets, product structures, investment strategies and/or terms and features. They are units in unregulated collective investment schemes (UCIS); securities issued by certain special purpose vehicles (SPVs); units in qualified investor schemes (QIS); and traded life policy investments (TLPIs). Note that not all pooled investments meet the statutory criteria for a ‘collective investment scheme’; pooled investment special purpose vehicles, notably, do not generally amount to a collective investment scheme.
The guide is also intended to enable us to satisfy the requirements of the FCA and Pensions Regulator in respect of tax wrappers, which captures small self administered schemes. It will apply to both retail customers and also sophisticated investors. The reason for this is that the Pensions Regulator makes no distinction in respect of it’s most recent requirements for improving member outcomes for SSAS of two persons or more.