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Asset Poolingmade simple
March 2010
Asset Pooling made simple
Acknowledgements
We would like to thank the following organisations for their help in producing and sponsoring this guide alongside KPMG
UK and KPMG Netherlands.
This guide is for information only. It is not investment advice.
Published by the National Association of Pension Funds Limited 2010 ©
First published: March 2010
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Contents
1 Introduction 2
2 What is asset pooling? 3
2a Definition 3
3 Why pool? 4
3a Diversification 4
3b Cost 4
3c Governance 4
3d Flexibility & Control 4
4 Key considerations 5
4a Legal and regulatory aspects 5
4b Tax aspects 6
4c Operational aspects 9
5 Common entity pooling vehicles 12
5a UK insurance companies 12
5b UK authorised investment funds 13
5c UK unauthorised unit trust 13
5d Dutch FGR structure 13
5e Luxembourg FCP structure 14
5f Irish CCF structure 15
5g Which to choose? 16
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Asset Pooling made simple
1. Introduction
Today, the investment universe in which pensions operate is vast and complex. An increasing number of asset classes,
investment strategies, and managers provide pension schemes with a variety of diversification options. This
diversification of schemes’ portfolios can pose problems in terms of implementation and governance. The more
diversification, the smaller the average mandate becomes. Properly implementing a relatively small allocation to a
certain asset class or strategy through segregated mandates (where single managers manage different parts of the
investor’s assets as a separate portfolio) may not be feasible. And even where it is feasible, the average cost of a
segregated mandate, tends to increase as the mandate becomes smaller.
Figure 1: Economies of scale in asset management
Rather than giving up on the goal of diversification, pooling represents a potential solution to this problem. Pooling
allows schemes to jointly invest their assets across different asset classes, strategies, and managers with other
investors and thereby enables pension schemes to optimally diversify their portfolio in a cost efficient manner.
This apparent win-win scenario has led many schemes to actively consider and pursue pooling.
There are two different ways to pool assets. One method, called pension pooling, is to merge two or more pension
schemes together, thereby creating a larger single pension scheme with higher levels of diversification at a lower cost
than the separate schemes. Another method, called asset pooling, is to jointly invest in specific asset classes,
strategies or managers with other investors. Since pension and asset pooling are quite different solutions with distinct
complications, this made simple guide focuses on asset pooling.
This document aims to make clear what asset pooling is, what the benefits are, the key issues that need to be
considered, and describe the key pooling structures that may be appropriate for UK pension schemes.
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2. What is asset pooling?
2a Definition
Asset pooling refers to the joint investment by multiple investors in a single portfolio of assets (the pool). This pool is
managed by a manager. This manager may manage the assets directly or it may be a multi-manager who appoints other
managers to each part of the pool. The parties involved can be other pension funds or they can be other types of
investors, such as charities or individuals (as illustrated in figure 2).
Figure 2: Asset pooling
Essentially asset pooling is the opposite of a segregated mandate, in which a manager manages part of the investor’s
assets as a separate portfolio.
In practice, there are two ways in which asset pooling can be structured: virtual pooling and entity pooling. With
virtual pooling, the investor still appoints a manager to manage a segregated account under an Investment Management
Agreement (IMA). However, the manager uses an administrative solution that enables the manager to manage multiple
segregated accounts as if they were a single, pooled account.
Entity pooling involves transferring the legal ownership of the assets to an entity in exchange for a ‘claim’ on the net
assets, such as a unit, share or participation. The value of this ‘claim’ is determined by the value of the assets and
liabilities held by the entity. While the pension scheme no longer legally owns the underlying assets, the ‘claim’ on the
assets is economically the same as owning them directly. This guide is focused on the more popular entity pooling.
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Asset Pooling made simple
3. Why pool?
The benefits of entity pooling occur in four key areas: diversification, reduced costs, enhanced governance,
and increased flexibility and control.
3a Diversification
Pooled funds enable pension schemes to diversify their investments across more asset classes, strategies and managers
than they might be able to achieve individually. In some asset classes, the minimum investment required for a
diversified segregated portfolio is considerable. Examples are asset classes that are “chunky”, such as private equity
and direct investment in property. The same problem can occur if the pension scheme wishes to diversify its
investments across multiple managers, whether these are alternative investment managers or more traditional
managers. In both cases, entity pooling represents a way to achieve diversification.
3b Cost
Even where a pension scheme is able to achieve its desired diversification through segregated mandates, entity pooling
can result in a lower overall cost of implementing the portfolio.
One reason is that management fees tend to be proportionately lower for larger mandates. If the manager of the pool
negotiates with the external managers for the pool as a whole, the pool manager should be able to achieve lower
management fees than would be the case for each pension fund separately.
The same logic applies to other management expenses related to custody, administration and voting, as well as to
potential sources of income such as commission recapture (whereby commission charges are controlled through
negotiations with brokers) and securities lending (the market practice whereby securities are temporarily transferred
by one party to another for a fee).
Transaction expenses may also be lower with entity pooling than with a segregated mandate, because an inflow into
the pool by one investor can be netted against an outflow from another investor, thereby avoiding the need for
transactions in the underlying portfolio. In addition, where there is a need for transactions in the underlying portfolio,
those transaction expenses may also be lower. The larger the pool, the larger the average transaction size will be. In
most cases the transaction costs will fall as the size of trade increases.
3c Governance
Although trustees will always remain responsible for the governance oversight, by employing a multi-manager to
manage the pooled fund, pension schemes are able to delegate the governance concerning manager selection to a
single multi-manager. As a result, trustees need to monitor fewer underlying managers and can spend more of their
time on setting, monitoring, and evaluating their overall investment strategy.
3d Flexibility and Control
By investing in pooled funds to gain diversified exposure across asset classes, pension funds are able to monitor and
manage their asset allocation in an efficient manner by making straightforward and timely asset allocation switches to
alter their investment strategy. This is an advantage when compared with investing in multiple smaller segregated
mandates, which can be complex, costly, and time intensive.
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4. Key considerations
Whether investing using a segregated mandate or a pooled fund, trustees should always take care to ensure that the
proposed investment is consistent with the scheme’s legal requirements and investment principles, and that the fees
and expenses are clear and acceptable. When considering entity pooling, there are three key areas that require special
attention before deciding whether to invest through a pooled fund. These are the legal and regulatory, tax, and
operational aspects of the pooled fund.
4a Legal and regulatory aspects
UK pension trustees are generally entitled to make use of pooling funds, whether the vehicles are established in the
UK or overseas. However, as pooling involves the transfer of the legal title of the underlying investments to a separate
entity, there are a number of legal issues trustees should consider in advance.
First, trustees should check that the structure of the pooled vehicle is consistent with the Occupational Pension
Schemes (Investment) Regulations 2005, particularly if the investment is a large proportion of the scheme’s assets.
Those regulations generally require schemes to invest predominantly in listed assets, but contain exemptions where
schemes invest in some (unlisted) pooling vehicles.
Secondly, trustees will need to be satisfied that they have fulfilled their fiduciary duties in using a particular pooled
fund. In the main, this involves ensuring that they have fully considered the effect of their decision, and have obtained
all necessary information to make a decision. So, for example, trustees will need to consider the following questions:
• What documents govern the pooled fund? Can the governing documents be changed without trustee
consent?
• Who owns the assets in the pooled fund? What is the risk of insolvency of the owner of the assets and
what will happen in that case? Are the assets kept safe by a custodian? If so, who is the custodian and
what will happen in case of insolvency of the custodian?
• Are there any restrictions on withdrawing from the pool? If so, are there any scenarios in which these
restrictions may not be in the interest of the pension scheme?
Finally, various procedural requirements are likely to apply. There may be a need to obtain written professional advice
before investing or to ensure that the decision, delegated by the trustee, is taken by an FSA authorised investment
manager. Trustees should look at the investment powers under their Trust Deed, and their Statement of Investment
Principles, and see whether they need revising (both of which may need some employer involvement or consent).
A UK pension scheme is legally allowed to participate in both regulated and unregulated pooled funds. However, the
scheme’s Trust Deed and Rules or Statement of Investment Principles may impose restrictions.
If a pooled fund is regulated, it will be regulated by the regulatory authority in the country where the fund is located.
And within a given country, there may be several possible regulatory regimes that can apply to the fund. Trustees should
therefore ensure that they determine the country where the fund is located, the identity of the regulator, and the
regulatory regime that applies to the pooled fund.
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Asset Pooling made simple
Investing in a regulated pooled fund is not necessarily better than investing in an unregulated fund. Depending on the
nature of the regulation, regulated pooled funds may provide additional comfort concerning the security of the assets
in the pooled fund. On the other hand, regulated pooled funds may also impose investment restrictions. For example,
regulated pooled funds under the European Union’s Undertakings for Collective Investments in Transferable Securities
(UCITS) regulation, which is primarily aimed at retail investors, currently restricts investment in certain asset classes,
for example commodities, private equity and direct investment in property, and in the use of derivatives. While
investing in an unregulated pooled fund will require greater due diligence, the restrictions imposed by regulated funds
are not necessarily in the interest of the pension scheme.
4b Tax aspects
One main objective of pooling is to ensure that, even though the underlying assets are no longer directly legally owned
by the pension scheme but by a pooling entity, the return on investment by participating in the pool is the same as
owning the underlying assets directly. Since pension funds typically benefit from tax exemptions, this means ensuring
that investing through a pooled fund does not lead to a higher tax burden.
In general, there are three types of taxes that can apply to pension schemes:
• Direct taxes
Direct taxes may arise at the pension scheme level, or at the pooled fund level in the form of withholding tax. As
above, direct tax should not arise at the investor level because of domestic tax exemptions available to pension
funds. Withholding tax may be deducted from distributions of income on investments, though the use of
transparent pools (as described below) can allow pension investors to retain the tax treaty benefits and thereby
secure the same rates of withholding tax as when investing in the underlying assets directly.
• Indirect taxes
VAT may arise on fees charged to the pooled fund.
• Transfer taxes
Stamp duty may arise on transactions in certain assets in the pooled fund.
When changing from investing using a segregated account to using a pooled fund, the tax situation may change
because the pooling entity may be subject to different taxation than the pension scheme itself, as illustrated in
Figure 3:
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Figure 3: Pooling tax considerations
From a tax perspective, there are two types of pooled funds: opaque and transparent (as described in figure 4).
Figure 4: Types of pooled funds
• Opaque pooled funds
An opaque pooled fund, on the other hand, is considered a separate legal entity that may be subject to taxation.
It is not necessarily true that an opaque pooling vehicle leads to higher taxation than direct investment by the
pension scheme. This depends on various factors, including the tax status of the pooled fund, the type of income
and gains generated by the investments and the countries being invested in. After paying taxes on income and
capital gains (if any) within the opaque pooled fund, the participant will generally only be taxed (if at all) on the
distributions made by the pooled fund and any gain on disposal of their participation.
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Asset Pooling made simple
In some cases, the difference between a direct investment and an investment through an opaque pooling vehicle
can lead to significant differences in return on investment (ROI).
In order to provide an illustration of the impact of tax on the return on investment (the tax drag or extra taxation),
figure 5 assumes a UK pension fund made an initial investment of £1 billion in European equities (as represented
by the MSCI Europe benchmark) in 2000. Using the estimated dividend yield on this investment for 2000 to 2009,
the estimated net-of-tax yields for an investment in a transparent and an opaque pooled fund are calculated. The
tax drag is assumed to be constant over time for the purpose of this modelling. In reality tax drag would vary each
year as country weightings, dividend yields and withholding tax rates vary over time. Over the period, the opaque
pooled fund results in a tax drag of £57 million over the period, equating to 57 basis points, compared to a
transparent pooled fund. This is a significant figure that could easily be doubled if investments were made outside
Europe, such as in the US.
• Transparent pooled funds
A transparent pooled fund so legal personality so is not considered a taxable entity by the tax authorities. In this
case, the pension scheme that participates in the pooling vehicle remains the beneficial owner of the underlying
investments and, as a result, is subject to the same taxation as if the securities were owned directly.
In order for this transparency to work, the transparency must be recognised by the country in which the income or
gains are generated, the country in which the pooled fund is located, and the country in which the pension scheme
is located. Countries use different criteria to determine whether or not an entity is transparent. These criteria
typically relate to legal concepts of ownership, which differ from country to country. For example, common law
countries use the concept of ‘beneficial ownership’, which is less familiar in civil law countries. Consequently, the
challenge for entity pooling is to identify an entity that is considered transparent by all target countries of
investment. Certainty can be achieved by seeking some form of ruling from the tax authorities. For example in
the UK, HMRC have been approached for rulings as to the transparent nature of many investment vehicles which
are listed in HMRC’s International Tax Manual 180030.
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Figure 5. Comparison of opaque and transparent pooling structures
Source: Northern Trust
4c Operational aspects
Pooled funds are considerably more demanding in terms of custody and administration than segregated mandates. The
participating pension scheme does not have to manage these aspects itself. This is the responsibility of the manager
of the pooled fund, who will generally appoint a custodian to perform some or all of these tasks. It is nevertheless
important for trustees to verify that the manager has taken appropriate measures to implement these operational
aspects of the pooled fund.
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Asset Pooling made simple
• Safekeeping
Whether assets are held in a segregated account or in a pooled fund, pension schemes should consider whether
their assets are properly ring-fenced so they are not affected by the insolvency of the manager. The key difference
is that, in the case of a pooled fund, the manager of the pool will generally take on some responsibility for
arranging the safekeeping.
• Trade settlement and corporate actions
In order to keep track of the assets that are held in the pooled fund, transactions need to be settled and corporate
actions need to be processed in a timely and orderly fashion. Once again, this also needs to occur in a segregated
mandate. The only difference is that, in the case of a pooled fund, the manager of the pool is responsible for
arranging these activities.
• Tax reclaims
The income generated by the investments of a UK pension scheme may be subject to withholding tax in the country
where the income and capital gains are generated. However, UK pension schemes can often benefit from lower
tax rates as a result of the Double Tax Agreements (DTAs) between the UK and other countries. Ensuring that the
tax burden for the pension scheme is minimised is already complex when a pension scheme invests using segregated
managers: in some cases, pension schemes can achieve tax relief at source, whereas pension schemes need to file
tax reclaims in other cases.
Organising the tax reclaim process in a pooled fund is potentially even more complicated, especially when the
pooled fund is tax transparent and has participants that are subject to different tax rates. This may occur when
the participants are from the same country but have a different tax status (e.g. a pension scheme and a retail
investor) or if they are from different countries (e.g. a UK pension scheme and a Dutch pension scheme). In that
case, it is not just the process of reclaiming taxes that becomes considerably more complicated. The distribution
of income and capital gains is also more complicated because different participants in the pooled fund will have a
right to different after-tax income and capital gains. This requires special fund accounting procedures, as
described below.
• Securities lending
When investing via a segregated manager, the pension scheme is in direct control over whether the securities held
by it are lent to third parties and, if so, the terms on which this lending takes place. When investing through a
pooled fund, these tasks are delegated to the manager of the pool subject to any terms concerning securities
lending in the pooled fund’s documentation. However, in some pooled fund vehicles, it is possible to organise
securities lending on a participant-by-participant basis. While this gives the participating pension scheme more
control over its securities lending within the pool, participant-level lending is administratively more complex as
participant-by-participant administration of the securities lent and collateral and fees received must be
maintained.
• Proxy voting
Institutional investors are under increasing political, social, and regulatory pressure to take an interest in how
voting rights are exercised. When investing in pooled funds, voting rights are exercised by the manager, subject
to any restrictions in the pooled funds’ documentation. A pension scheme should ensure that the manager reports
on their policies regarding voting rights.
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• Fund accounting
Fund accounting is the maintenance of books and records of a pooled fund to accurately record and value the
assets, liabilities, income and expenses in accordance with the laws and regulations of the jurisdiction where the
pooled fund is located. This process culminates in the calculation of the Net Asset Value (NAV) of the pooled fund,
the number of shares, rights, or participations issued by the pooled fund to each participant, and the Net Asset
Value per share, right, or participation.
Fund accounting for pooled funds becomes complicated when there are differences between the participants.
These differences may be due to differences in tax status, in country of origin, or in participation in securities
lending. In that case, the fund accounting must take place not only at the level of the fund, but also at the level
of each share class, which represents a group of participants that are identical in terms of accounting treatment.
This process is illustrated in Figure 6 below.
Figure 6. Fund accounting in a (transparent) pooled fund
In short, entity pooling can lead to additional complications in the operational aspects associated with the
administration of the pool and the rights of the individual participants. While the manager of the pooled fund is
responsible for organising these aspects – and will generally do so by appointing a custodian for some or all of the
operational aspects – trustees should determine prior to participating in a pooled fund how these aspects are organised
and what, if any, residual risks these imply for the pension scheme.
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Asset Pooling made simple
5. Common entity pooling vehicles
Common types of pooling vehicle used by pension schemes are:
• UK Insurance companies
• UK authorised investment funds
• UK unauthorised unit trusts
• Dutch Fonds voor Gemene Rekening (FGR)
• Luxembourg Fonds commun de Placement (FCP)
• Irish Common Contractual Fund (CCF)
Historically, UK pension funds have used insurance companies and authorised funds to pool with other UK pension
schemes and/or other types of UK investors.
UK pension schemes can, however, also use the Dutch FGR, Luxembourg FCP, and Irish CCF as vehicles for entity pooling.
One benefit of these vehicles is that they facilitate cross-border pooling: pooling by investors from different
jurisdictions. These European vehicles were first used by UK pension schemes to pool with the overseas pension
schemes of the same corporate sponsor. But these vehicles can also be used to pool the assets of unrelated pension
schemes from one or more countries. In fact several asset managers are now offering pooled funds that use these
European vehicles to offer pooling to pension schemes in a variety of countries. As financial markets are likely to
continue down the path of internationalisation, the Dutch FGR, Luxembourg FCP, and Irish CCF are likely to become
increasingly common pooling vehicles for use by UK and wider European pension schemes.
In the following paragraphs we will discuss the key legal, regulatory and tax aspects of the aforementioned pooling
vehicles.
5a UK insurance companies
It is common for asset managers to establish insurance companies in order to offer the pooling option to UK pension
schemes.
Legal and regulatory aspects
By participating in a UK insurance company fund, the legal title to the assets is transferred to the insurance company
in exchange for an insurance policy.
Unlike other entity pooling vehicles, the insurance company is subject to the FSA’s capital requirements for life
insurance companies. These capital requirements are however typically minimised by matching assets closely with
liabilities.
The insurance company is regulated by the FSA.
Tax aspects
UK insurance companies are opaque for withholding tax purposes but they can access the UK’s extensive range of tax
treaties. This means that investment through a UK insurance company is tax efficient for a UK pension scheme. For
example, a Competent Authority Agreement was agreed in 2005 that enables pension fund business of insurance
companies to qualify for the zero per cent rate of US withholding tax.
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5b UK authorised investment funds
Asset managers also commonly offer pooling via a UK authorised investment fund, i.e. an open-ended investment
company (OEIC) or an authorised unit trust. In practice, managers tend to combine the benefits of authorised funds
and insurance companies by using a hybrid structure which allows pension funds to invest in a range of widely held
authorised funds, via an insurance policy.
Legal and regulatory aspects
By participating in a UK authorised investment fund, the legal title to the assets is transferred to the fund in exchange
for a share or unit.
An advantage of UK authorised investment funds over UK insurance companies is that they can be used to pool the
assets of UK pension schemes together with the assets of other types of UK investors for example individuals and
charities.
UK authorised investment funds are subject to regulation by the FSA. As such, they are subject to the FSA’s investment
and borrowing rules.
Tax aspects
UK authorised investment funds are not transparent for withholding tax purposes and are subject to different tax rates
than UK pension schemes. As a result, these vehicles can be less tax efficient when investing in certain asset classes
(e.g. US equities). However, UK authorised funds are able to access the UK’s tax treaties so are generally efficient.
5c UK unauthorised unit trust
Another common UK entity pooling vehicle is the unauthorised unit trust (UUT).
Legal and regulatory aspects
By participating in a UUT, the legal title to the assets is transferred to the trust in exchange for units.
UUTs are not authorised by the FSA. They are therefore not subject to the FSA’s investment and borrowing rules. As
a result, UUTs are often used for pooling investments in asset classes such as private equity and direct investment in
property.
Tax aspects
UUTs are not transparent for withholding tax purposes and are subject to different tax rates than UK pension schemes.
As a result of their UK tax status, UUTs are generally only used by UK pension funds and UK charities. Like insurance
companies, UUTs can be efficient for investing in US equities as they are covered by the above Competent Authority
Agreement.
5d Dutch FGR structure
The Fonds voor Gemene Rekening (FGR) has been used in the Netherlands since the late 1960’s as the Dutch equivalent
of the UK unit trust for the pooling of Dutch pension scheme assets. The FGR is a well-established entity pooling vehicle
which has the support of a broad network of DTA Treaties negotiated by the Dutch government, the FGR has more
recently started to be used for pooling pension assets of non-Dutch pension schemes, including schemes in the UK.
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Asset Pooling made simple
Legal and regulatory aspects
The FGR is a contract-based pooled fund where the participants enter into a contract, with the manager and depositary
of the pool. On participating in an FGR, the assets are transferred to a stichting (similar to a UK trust) that acts as the
manager and depository of the pool. In exchange, the participants receive a ‘claim’ on the assets, known as a share
or participation in the fund.
The FGR can be regulated or unregulated. In practice, most FGRs that are used by pension schemes are unregulated
to achieve maximum efficiency. However, the participants and the manager may agree to comply with a light
regulatory regime or UCITS regulation by the Dutch Authority for Financial Markets (AFM). The FGR contract is very
flexible in terms of governance, investments and fee structure.
Tax aspects
The FGR can be structured as an opaque or a transparent vehicle for withholding tax purposes, whichever is optimal
given the nature of the underlying investments. The FGR is not subject to Dutch corporate tax and management fees
are exempted from Dutch VAT. As a result, a wide variety of investors, including UK pension schemes, can participate
in the FGR.
One advantage of the Dutch FGR is that the contract can be structured so as to support participant-level securities
lending. This provides participants with the option to implement a bespoke securities lending policy that is different
from the policies of the other participants.
5e Luxembourg FCP structure
Luxembourg offers the investment fund industry a modern legal and tax environment. The continuing development of
Luxembourg as a centre of financial and investment fund services has led to a concentration of specialist service
providers there. Moreover, Luxembourg has an established reputation as a fund centre.
Legal and regulatory aspects
Like the FGR, the Luxembourg Fonds commun de Placement (FCP) is a contract-based pooled fund with no separate
legal personality. A FCP must therefore be managed by a Luxembourg management company on behalf of joint owners
who retain ownership of the underlying assets. Investor’s liability is limited to contribution and capital commitment.
The Commission de Surveillance du Secteur Financier (CSSF) provides regulatory oversight.
The FCP may segregate its assets into separate pools or sub-funds. Each sub-fund’s liability is ring fenced (explained in
section 4.3). As well as being UCITS structured, the FCP can be established as a non-UCITS fund with reduced assets
restrictions and relaxes regulation.
Tax aspects
The FCP is tax transparent for Luxembourg purposes, but, as with all funds, transparency also depends on the approach
of the tax authorities in the countries of investment.
Services rendered directly to an FCP are currently exempted from VAT if they qualify as “management services of
investments funds”. Services covered by this definition are administrative services and investment advice services.
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5f Irish CCF structure
The Common Contractual Fund (CCF) was established in 2003 as a tax efficient way for pension funds and institutional
funds to pool their investments together. The Irish industry’s capacity and scale to service and meet all CCF reporting
requirements, has positioned the Irish CCF as an optimal investment pooling structure.
Legal and regulatory aspects
The CCF is a contract-based fund with no separate legal personality and is transparent for Irish legal and tax purposes.
The Irish CCF is governed by Irish law and is regulated by the Irish Financial Services Regulatory Authority.
If a CCF is established as a UCITS fund it is subject to the investment objectives and policies relevant to UCITS funds.
If however the fund is a non-UCITS fund it can make use of the broader investment objectives and policies that are
available to non-UCITS. This allows for a large degree of flexibility in investment style. CCF can also be structured as
umbrella funds with multiple sub-funds within the one fund structure.
Tax aspects
As the CCF is a tax transparent vehicle, this means investors should still have access to tax treaty relief in the investor’s
home country. As with the FGR and FCP, this ultimately depends on the view of the tax authorities in the countries of
investment.
5g Which to choose?
In practice, the choice of which vehicle to choose depends on non-tax factors. For a fund to be on the short list,
an appropriate tax and regulatory structure are given. Instead, the choice depends on the capability of the
management company and its administrators to service a product and the location of the operators’ existing products.
All the funds listed above would be credible options for most UK schemes.
It is likely that competition between jurisdictions will increase in coming years as pooling techniques develop and have
wider application, following the implementation of UCITS IV in July 2011.
Ultimately, in deciding between these jurisdictions and structures, pension fund investors should aim to be no worse
off as a result of pooling their investments than if they had invested directly in the relevant investments held by the
vehicle on their behalf.
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Asset Pooling made simple
The National Association of Pension Funds Limited 2010 ©
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March 2010
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