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FSCA Expectations of CIS managers during COVID-19

The FSCA published Communication 23 of 2020 (CIS) recently to acknowledge the impact of the COVID-19 global pandemic on collective investment schemes and their investors. The focus of the communication is specifically to outline certain expectations of the FSCA regarding the duties of managers of collective investment schemes and their responsibility to ensure that all customers are treated fairly during the national lockdown.

The Communication highlights, amongst others, the following:

Provides steps to ensure compliance with portfolio risk limits;
Acknowledges the acceptance of electronic signatures on supplemental deeds to approve changes to portfolios;
Emphasises the reporting of liquidity constraints; and
Stresses the importance of communication with investors.

Although the FSCA understands the operational challenges that managers are facing in this current situation and that there may be variations in their forms of communication with investors during this period, it is important that all communication is monitored. Managers must also apply the necessary security measures in order to ensure the optimal safety of their investors’ information and of the business at large.

In addition, the FSCA encourages managers to continue to actively communicate with investors during this time and to ensure that necessary measures are taken into account to resolve customer complaints timeously and that turn-around-times on resolving complaints through any channels are not compromised.

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