Thematic Review of Unclaimed Client Money of Collective Investment Schemes

The Commission has today issued its report on the Thematic Review of Unclaimed Client Money of Collective Investment Schemes (“the Thematic”). The Thematic was undertaken in order to gain a better understanding of the value of unclaimed and unallocated monies in the collective investment scheme industry in Guernsey and how these monies are dealt with by the relevant parties. The Commission engaged with 41 Designated Administrators, which included the vast majority of Designated Administrators regulated by the Commission as at July 2022, and all active Guernsey collective investment schemes were within the scope of the Thematic.

The Commission identified that, as a proportion of the collective investment scheme industry’s overall NAV, Unclaimed Money does not represent a significant percentage but it is recognised that the scope of the Thematic did not include surrendered collective investment schemes where, for example, all monies other than unclaimed monies may have been distributed. Further, whilst industry-wide the total unclaimed money figure is proportionately small, it may not be small for the individual investors involved.

The Commission also identified that unclaimed money is not dealt with in a consistent manner within the collective investment scheme industry and this may be as a result of limited guidance and rules relating to this matter. The Commission will consider issuing a consultation paper in due course which will seek industry’s views on key points which may be covered in any future guidance or rules.

A copy of the Thematic Review is available via the following link:

2023 Thematic Review of Unclaimed Client Money of Collective Investment Schemes.pdf

The Commission would encourage licensees and collective investment scheme boards to consider the contents of the report, in particular how the example of good practices may be applied.