Board Notice 92 of 2014 was promulgated in August 2014. It prescribed disclosure requirements, and came into effect on 1 May 2015. The Registrar adopted a phase-in approach in order to allow Managers time to gain an understanding of what is expected of them in relation to compliance with the Notice.
Information Circular 26, issued on 5 April 2016, provides details of how the Regulator intends start applying the prescriptions of the Notice. This includes imposing penalties from 1 May 2016 on all CIS managers who fail to comply.
It appears that certain managers are not aware of material produced by third-party portfolio managers. In many cases this material is not compliant with the law. The Registrar reminds managers that they retain full liability and accountability for these portfolios.
Please click here to download the detailed information circular.