Submission: Review of the regulatory framework for managed investment schemes

In 2023, the Australian Government undertook a review of the regulatory framework for managed investment schemes (MIS).

The review's aim was to examine whether the regulatory framework was fit‑for‑purpose, identify potential gaps, and consider what enhancements could be made to reduce undue financial risk for investors. It assessed the appropriateness of regulatory settings for managed investment schemes including:

• the thresholds that determine whether an investor is a wholesale client
• whether certain managed investment schemes should be marketed and sold to retail clients
• the roles and obligations of responsible entities
• whether ‘investor rights’ are appropriate
• liquidity requirements for managed investment schemes
• whether an insolvency regime is required for managed investment schemes
• interactions between Commonwealth and State laws when regulating real estate investments by managed investment schemes.

As part of the review, Treasury released a consultation paper, on which Aussie Angels (now Ventari) made a submission.

Our submission was supported by Startmate and Kate Morris, Co-founder of Adore Beauty and Glow Capital Partners. It addressed the aspects of the review relevant to angel investors and fund managers, in particular the question of raising wholesale investor thresholds.

Our submission outlined the significant unintended negative consequences that could arise from this for female investors, and for Australia's technology and small business sectors with likely flow-on effects for the broader economy.

Following the review, wholesale investor thresholds remained unchanged.

You can read our full submission here.