18 Nov 2020

AREF and the IA have drafted a joint response to HMRC’s consultation on ISAs and authorised open-ended property funds. We welcome members views on this response. Please send these to Jacqui Bungay (jbungay@aref.org.uk) by Friday 27 November.

Background to consultation

FCA’s CP20/15 Liquidity mismatch in authorised open-ended property funds proposes to introduce a requirement that investors in open ended property funds must provide between 90 and 180 days’ notice before their investment can be redeemed. The proposal has implications where such investments are held within an Individual Savings Account (ISA), as the ISA legislation requires account holders to be able to access the funds or transfer them to another ISA within 30 days of making an instruction to their account manager.

In order to mitigate the impact on ISA account holders and managers if the FCA introduce the proposed change, the Government is considering the idea of allowing existing investments in open-ended property funds to remain within the ISA whilst prohibiting the inclusion of ‘new’ investments in such funds. The aim of this consultation is to gather views on the viability of such a proposal. The deadline for responses is 13 December 2020.

HMRC are particularly interested in hearing from ISA managers and others involved in the investment industry who have experience of including property funds within a client’s ISA portfolio; Investors in daily dealing property funds via their stocks and shares ISA and representative bodies of any of the above groups. We would encourage AREF members to advise any of these stakeholders, that they have contact with, of the consultation.


Jacqui Bungay

Jacqui Bungay

AREF Policy Secretariat , AREF

Jacqui provides policy guidance and secretariat services to the AREF Board and AREF Management Committee as well as the following AREF Committees: Corporate Governance, ESG & Impact Investing, Investor, Public Affairs, Research and Information and Retails Funds. In addition, Jacqui monitors members’ compliance with AREF’s Code of Practice. 

Jacqui joined AREF in 2014 after working for over 25 years in fund compliance, client relationships and administration at Natwest Trustee & Depositary Services.