The introduction of notice periods is the simplest way of achieving a greater match between the liquidity of units and the liquidity of underlying assets, but is still problematic for many funds particularly if the platform architecture for retail investors cannot accommodate this. Some of the practical problems noted in our 2017 AREF report, such as investment by ISAs, are flagged in the consultation but no solution is proposed as yet.

Overall, it is slightly disappointing that the FCA again want a "one size fits all" solution that does not give the retail investor greater choice, albeit that it is probably a better "one size fits all" solution than doing nothing.

The devil will again be in the detail, but the consultation runs until November so there is time for the industry to respond.

3rd August 2020