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Home Forums Australian Financial Services Licensing (AFSL) Forum Starting an Unregistered Investment Scheme as a Fund Manager

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  • #5380 Reply


    Hi All,

    Looking for some advice on starting an unregistered investment scheme. I will be the fund manager, trustee and custodian of the Investment fund and also looking to initially handle all of the administration. I have done hours of research and have come up with a list of steps to take, can anyone tell me if these are the correct steps or if I need to add in any steps? Any advice would be much appreciated.

    1.  Become an authorized representative of AFS Licensee with the correct authorities.

    2. Set up my funds management company as a proprietary company

    3. Set up the unit trust

    4. Raise Capital through wholesale investors and 2/12/20 exemption (2 million from 20 retail investors in a 12 month period) using an Information Memorandum.

    5. Operate as an unregistered fund for 3 years (50 or less investors)

    6. After 3 years of experience in this I can apply for my own AFSL and become a Responsible Manager along with a second Responsible Manager. At his stage I would also register the investment scheme and change my funds management company from a private company to a public company to allow for more than 50 investors. Through the AFSL I can also act as the responsible entity of the fund.

    7. After this I can market to both retail and wholesale investors via a PDS.

    From what I have found online this is what I have come up with, again any advice would be greatly appreciated.

    #5389 Reply

    David Court

    Hi Jason,


    We do admire your extensive and fairly detailed plan. However responding to your request involves giving you legal advice that we are not able to provide over this forum. We are happy for you to come in and discuss your plans with one of our lawyers. An initial one hour consultation will cost $660 (including GST).


    Please let me know if you would like to take up the opportunity.


    You can contact our Finanical Services Team if you would like further assistance


    Author: David Court (Partner).

    Co-contributor: Hugo Sasse (Law Clerk).

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