Financial Markets Conduct (Vision Invest NZ Funds) Exemption Notice 2025

Summary

The Financial Markets Conduct (Vision Invest NZ Funds) Exemption Notice 2025 (Notice) exempts FundRock NZ Limited (FundRock) in respect of the Vision Income Fund (Fund) from certain disclosure provisions of Schedule 4 of the Financial Markets Conduct Regulations 2014 (the Regulations) relating to details being provided on Disclose Register about loans made by FundRock NZ Limited (FundRock) that are assets of the Fund.  The exemption is subject to alternative disclosures being provided to investors.

In summary, the manager is required to provide the following alternative disclosures:

the term and security asset for the loan;

• information about the Fund's composition i.e., according to various security asset types and by loan term;
• how many loans have been advanced by the Fund and the 10 largest loans as a percentage of the value of the Fund; and
• risk rating information for each of the loans in the Fund, and a breakdown of the percentage of loans according to each risk rating.

The key reasons for granting the exemption are that –

• it avoids unnecessary compliance costs for FundRock.  Entities who borrow from the Fund may need to provide consent to FundRock so that FundRock could disclose the borrower’s name on the Register.  This would have a compliance cost for FundRock.  However, it is unlikely that an investor would be able to obtain useful information about a loan asset from the name of the borrower because such information is unlikely to be publicly available.  Additionally, the name of the borrower is not information which would help an investor to monitor the investment practices of the fund manager or help an investor assess whether those practices are consistent with the fund’s investment philosophy as set out in the SIPO.  The FMA considers that this compliance cost is unnecessary.
• the alternative disclosure would provide more useful information to investors about the loan assets because the term of the loan will assist investors identifying their exposure to short term and long term economic volatility.  Additionally, the security type and the risk rating information will assist investors with establishing the risk exposure of the Fund, and the manner in which the alternative disclosure information will be presented will be more easily understood by a broader range of investors.
• the FMA also considers that if the names of borrowers were publicly disclosed it may constrain the ability of the Fund to attract borrowers. As such, the exemptions, together with the conditions, will promote the confident and informed participation of businesses, investors, and consumers in the financial markets.

Download the Financial Markets Conduct (Vision Invest NZ Funds) Exemption Notice 2025