1.3 Participants in the CIS Ecosystem: Unit Holders, Managers, Trustees, Distributors and Regulators

FIMM Combined Examination FCE

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1 Introduction: The FIMM Combined Examination (FCE)

0.1 FCE Exam Facts, Registration Rules and How to Use This Guide

2 Chapter 1: Understanding Collective Investment Schemes in Malaysia

1.1 What a Collective Investment Scheme Is and How Malaysian CIS Are Classified 1.2 Investment-Linked Funds Are Not UTS; Industry Growth and History 1.3 Participants in the CIS Ecosystem: Unit Holders, Managers, Trustees, Distributors and Regulators

3 Chapter 2: Introduction to UTS and PRS

2.1 UTS and PRS as Investments: Mechanics, Unit Calculations and How They Compare 2.2 Types of Funds: By Asset Class, Fund Structure and Investment Objective 2.3 Methods of Investing and Dollar Cost Averaging 2.4 Benefits and Disadvantages of Investing in UTS and PRS 2.5 Understanding Risk and the Risks of Investing in Schemes 2.6 Shariah-Compliant Schemes, Their Risks and the Role of the Shariah Advisory Council

4 Chapter 3: Regulatory Framework

3.1 The Regulatory Framework: The SC, Other Regulators and FIMM's Dual Role 3.2 Legislation, SC Guidelines and FIMM Rules Governing UTS and PRS 3.3 Regulation of Scheme Providers and Oversight Functions 3.4 The Deed, the Prospectus or Disclosure Document, and the Product Highlights Sheet 3.5 Portfolio Constraints: Permitted Investments, Liquidity, Borrowing and Exposure Limits 3.6 Regulations for Other CIS: Real Estate Investment Trusts and Exchange-Traded Funds 3.7 Regulation and Duties of the Scheme Trustee 3.8 Regulation of Marketing and Distribution: Distributor Categories, Collection Points and Agency Structure 3.9 Registration of Consultants: Eligibility, Fit and Proper, Duration, Variation and Revocation

5 Chapter 4 (Part 1): Marketing and Distribution — Disclosure and Transactions

4.1 Servicing Investors and the Contents of the Prospectus and Disclosure Document 4.2 The Product Highlights Sheet, Advertising Standards and Account Maintenance 4.3 The Purchase Process and Suitability Assessment Before Personal Advice 4.4 Cooling-Off Rights, Repurchase of Units, Suspension and Switching 4.5 Financing the Purchase of UTS: Process, Safeguards and the Risk Disclosure Statement 4.6 EPF Transfers and Withdrawals for Investment in Approved Unit Trust Funds

6 Chapter 4 (Part 2): Marketing and Distribution — Distributions, Reporting and Service

4.7 Distributable Income, Distributions and NAV, "Buying" a Distribution and Taxation 4.8 Reporting to Investors: Confirmations, Statements, and Semi-Annual and Annual Reports 4.9 Marketing Principles, Delivering Quality Service and Handling Complaints 4.10 The Effect of Inflation, Taxation and Investment Costs on Returns 4.11 Investment Alternatives to UTS and PRS

7 Chapter 5: Code of Ethics

5.1 Compliance, Ethics and the Structure of the FIMM Code of Ethics 5.2 Core Principle 1: Honesty and Integrity 5.3 Core Principle 2: Professionalism 5.4 Core Principles 3 to 5 and Non-Compliance: Conflicts, Disclosure, Confidentiality and Misconduct

8 Chapter 6: Personal Financial Planning

6.1 Personal Financial Planning: Definition, Features, Five Areas and the Six Steps 6.2 Financial Planner Credentials, Skills, Remuneration, and How a Planner Differs from a Consultant 6.3 The Consultant's Role in Investment Planning and Advising Clients Through the Life Cycle

9 Chapter 7A: Features and Operations of UTS

7A.1 Structure of a UTS, the Trust Deed, the Parties and Modifying the Deed 7A.2 UTS Fees, Charges and Expenses, and the Management Expense Ratio 7A.3 Dealing in Units, Valuation, NAV Calculation and Unit Prices 7A.4 Forward and Historical Pricing, and the UTMC's Holding of Units 7A.5 Unit Splits, Distributions and Their Effect on NAV 7A.6 Measuring UTS Performance: Returns, Performance Tables, Risk Measures and Qualitative Factors 7A.7 Operational Aspects of Shariah-Compliant UTS and PRS and the Shariah Contracts Between the Parties 7A.8 Borrowing to Invest in UTS and the Risks of Loan Financing

10 Chapter 7B (Part 1): The Pension Landscape and the PRS Framework

7B.1 The Malaysian Pension Landscape and the Adequacy of Retirement Savings 7B.2 The World Bank's Five-Pillar Pension Framework in the Malaysian Context 7B.3 Key Players: EPF, KWAP, LTAT, Employer-Sponsored Schemes and Annuities 7B.4 Why Malaysia Needs PRS: Ageing, Longevity Risk and the Benefits of PRS 7B.5 The PRS Framework and the Private Pension Administrator (PPA) 7B.6 PRS Structure, the Trust and Deed, Advantages over Other Products, Eligibility and Contributions

11 Chapter 7B (Part 2): PRS Operations

7B.7 The PRS Default Option and Tax Incentives for Members and Employers 7B.8 The PRS Account Structure (Sub-Accounts A and B) and Vesting 7B.9 PRS Withdrawals: Pre-Retirement, Retirement, Permanent Departure, Incapacity and Death 7B.10 Switching Between Funds and Transferring Between PRS Providers (Portability) 7B.11 Unclaimed Monies, Death of a Member and PRS Nomination 7B.12 PRS Funds: Number, Core and Non-Core Funds, Objectives, Risk Profiles, Asset Classes, Authorisation and Naming 7B.13 PRS Fees, Charges and Expenses 7B.14 PRS Unit Creation, Forward Pricing, Valuation, Distributions, Performance Measurement and Electronic Communication

1.3 Participants in the CIS Ecosystem: Unit Holders, Managers, Trustees, Distributors and Regulators

Key Takeaways Explain This Topic AI

FIMM's study guide lists the CIS participants as investors or unit holders, the Trustee, the Management Company, the regulators and the dispute-resolution body.

Unit holders cannot require the fund's assets to be transferred to them and are not liable to indemnify the manager or Trustee if liabilities exceed the fund's assets.

A Management Company may outsource investment management, fund accounting and the register of unit holders, but the ultimate responsibility stays with it under the UTF and PRS Guidelines.

The Trustee must be registered with the SC and protects investors by holding the fund's assets in its name and ensuring the Management Company follows the deed and offering documents.

The Financial Markets Ombudsman Service (FMOS) was established on 1 January 2025 by consolidating the Ombudsman for Financial Services and SIDREC.

Last updated: October 2026

The Ecosystem in One Picture

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FIMM's practice question lists the participants as investors/unit holders, the Trustee, the Management Company, regulators and dispute resolution . A consumer association is not one of them.

Unit Holders

A unit holder is legally recognised as an investor in the fund. Unit holders can be individuals, companies, institutions, government bodies, charities, societies, associations, trusts and even other CIS.

Their rights are set out in the deed and the offering document :

Scheme Offering document
UTS Prospectus
PRS Disclosure document
Wholesale fund Information memorandum

If the offering document is not detailed enough, the unit holder can refer to the deed, usually by requesting a copy from the Management Company's registered office.

Rights include receiving distributions (if any), sharing in the capital value of units and any other rights in the deed. Limits on those rights:

A unit holder cannot demand that fund assets be transferred to them.

A unit holder cannot interfere with or question the Trustee when it exercises its rights as the registered owner of the fund's assets.

Liability is limited : a unit holder is not liable to indemnify the fund manager or Trustee if their liabilities exceed the value of the fund's assets.

The Management Company

The Management Company (a UTMC for UTS, a PRS Provider for PRS) establishes, offers, markets, operates and administers the scheme. Because it carries out regulated activities under the Capital Markets and Services Act 2007 (CMSA) , it must be licensed by the SC .

It may outsource functions, but ultimate responsibility remains with the Management Company under the SC's UTF and PRS Guidelines. Commonly outsourced functions:

Function What is outsourced

Investment management An external fund management company (domestic or foreign, licensed) handles stock selection, research and asset allocation

Fund accounting / administration Valuing investments, computing NAV, preparing financial statements, dealing with auditors

FIMM's practice question tests the false statement "a Management Company must not outsource any of its functions".

The Trustee

The Trustee is an independent party that must be registered with the SC . It protects unit holders in two ways:

Safeguarding assets – all fund assets are held in the Trustee's name on behalf of the fund.

Monitoring the manager – it checks that the Management Company follows the deed and offering documents, carrying out independent reviews instead of relying only on what the manager reports.

A Trustee may appoint agents such as a custodian , and a custodian may appoint a sub-custodian (for example within its global group, or in countries where it has no presence). The arrangement must ensure fund assets are:

clearly identified as the fund's assets;
held separately from other assets held by the Trustee; and

registered in the Trustee's name, or in the custodian's name to the order of the Trustee.

The Trustee remains responsible for the actions of any agent it appoints.

Distribution Channels

A Management Company may use its own sales team and other channels. For UTS and PRS these are the UTS agency force, IUTA, IPRA, CUTA and CPRA (Chapter 3 explains each). Choosing channels is a commercial decision for the Management Company, but it must ensure its channels comply with the rules.

Regulators and FIMM

The SC is the primary regulator of CIS.

BNM is involved for anti-money laundering, countering financing of terrorism and targeted financial sanctions, and for foreign exchange matters.

Foreign regulators are involved when a CIS is offered under a passporting scheme (the ASEAN CIS framework) or a mutual recognition arrangement (for example Hong Kong or the Dubai International Financial Centre).

FIMM is a self-regulatory organisation (SRO) mandated by the SC to oversee the marketing and distribution of UTS and PRS. It regulates UTMCs, PRS Providers, IUTAs, IPRAs, CUTAs, CPRAs and individual UTS and PRS Consultants.

Oversight Functions

The study guide's Table 1.4 adds an oversight function that checks the fund is managed according to its deed, prospectus, internal restrictions and the Guidelines. It can be an individual (who must be independent of the functions overseen) or a committee (which may include some non-independent members if it can still do its job). Nobody performing the oversight function may also be a member of the Shariah adviser for the same fund. If the manager does cross-trades between funds or client accounts, the oversight function must approve the cross-trade policy and receive details of each cross-trade.

Dispute Resolution: FMOS

The Financial Markets Ombudsman Service (FMOS) was established on 1 January 2025 by consolidating the Ombudsman for Financial Services (OFS) and the Securities Industry Dispute Resolution Center (SIDREC) . It is appointed by BNM and the SC to resolve disputes between financial consumers and financial service providers independently, fairly and in a timely way, without taking sides and on the facts of each dispute.