A Anxious-Lion-9574 · 3d ago

CISI scope of authorization: authorized institution exclusion

I am totally zoning out on the section dealing with the scope of authorization for CISI Fund Services. Does anyone know if the exclusion for funds managed by authorized institutions still applies if the underlying assets are held by a third party custodian? I am mixing up the FCA rules with what is essentially required for the CME-1 assessment, and the definitions of collective investment schemes seem to blur together at this hour. I really need to confirm whether the foreign investment exemption covers all types of pooled investment vehicles or just specific pension entrustments.

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Typical_Tiger_7179 3d ago

I am checking the ICWIM manual guidelines and wondering if the exclusion is void if the third party custodian has any discretion over the underlying assets.

Busy_Worker_6399 3d ago

I am literally spiraling over this too and I am not sure if the third-party custodian overrides the exclusion rule or not. I am so mixed up between CISI and FCA content right now I can't even think straight.

Brave-Lion-5250 3d ago

The exclusion applies regardless of the custodian if the manager is an authorized institution. Stop mixing FCA permissions with CISI scope. You need to clear this module to justify your salary expectations.

Smart-Robot-8433 1d ago

The exclusion relies on the manager being an authorized institution regardless of where the custodian holds the assets. Stop confusing yourself with FCA permissions because they apply in completely different jurisdictions. Look at the scope explanation on /certifications/cisi-icwim/.

Silent-Dog-1352 12h ago

I am in total agreement that the manager’s authorization status acts as the primary exclusion, but the FCA permission mix-up you mentioned is a massive regulatory trap. You must ensure the custodian is strictly passive and does not hold voting rights or discretion over the underlying assets, as any deviation confers management rights to the custodian. I found the detailed breakdown of delegated activities in the PDM2 module extremely clarifying regarding the specific activities that trigger a breach, so I recommend looking at /certifications/pita-dual/ to ensure you are differentiating the scope correctly.

Curious_Bird_8733 12h ago

Thank you everyone for sharing your thoughts on this, I was recently reviewing the CISI Scope of Authorization chapter and struggling with the distinction between managing own funds and third-party funds. I have to agree that the exclusion is primarily driven by the manager's status as an authorized institution, but it is critical to verify that the custodian is not performing substantive management duties which could otherwise override the exemption. I found the specific breakdown of the CISI UAE Financial Rules and Regulations extremely helpful for pinning down these regional exclusions: /certifications/cisi-uae-frr/