Managed Investment Scheme
Managed Investment Scheme (MIS) is defined in section 9 of the Corporations Act 2001 (Cth). In plain terms, three elements must be present: people contribute money or money's worth to acquire rights to benefits, those contributions are pooled or used in a common enterprise to produce benefits for members, and the members do not have day to day control over the operation of the scheme. Most pooled mortgage funds and contributory mortgage funds are managed investment schemes.
Why It Matters
Whether an arrangement is an MIS determines the entire regulatory perimeter around it, including licensing, registration, disclosure, and who can be offered an interest. Property syndicates, pooled mortgage funds and contributory mortgage funds routinely fall within the definition even where the operator did not set out to create a fund. An interest in an MIS is a financial product, which is why the wholesale client test rather than the sophisticated investor test is usually the relevant one.
How It Works
- A scheme generally must be registered with ASIC where it has more than 20 members, or is promoted by a person in the business of promoting schemes, and is offered to retail clients.
- A registered scheme must have a responsible entity: a public company holding an Australian Financial Services Licence authorising it to operate the scheme. The responsible entity holds scheme property and operates the scheme, and owes duties to members.
- A scheme offered only to wholesale clients may be operated as an unregistered scheme, which is the structure used by most wholesale private credit and mortgage funds.
- Unregistered does not mean unregulated. Operating an unregistered wholesale scheme still ordinarily requires an appropriate AFS licence authorisation or a valid exemption.
Common Use Cases
- Pooled mortgage funds lending across a portfolio of loans
- Contributory mortgage funds where investors select individual loans
- Property development syndicates raising investor capital
- Wholesale private credit funds offered under an information memorandum
Related Switchboard Resources
- Wholesale Client
- Wholesale Investor
- Product Disclosure Statement
- Information Memorandum
- Loan to Value Ratio
- Private Lending
For ASIC guidance on managed investment schemes, visit asic.gov.au.