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In most cases subscriptions and redemptions are netted off by the manager and the full subscription price is only applied to the net subscriptions. Remaining investors are not diluted but investors who get their timing right can buy at a discount and sell at a premium In a model where the full subscription price is applied to all inflows, even where these are used to fund redemptions rather than to acquire underlying assets, this results in a notional “premium” for the benefit of existing investors over and above the price required to ensure that they are not diluted, but also ensures that all investors suffer a round trip cost on subscribing and redeeming that reflects the cost of buying and selling the underlying assets.


A swinging price means that investors can make significant returns by buying units at the redemption price and selling them at the subscription price when the price swings. At the time of our report, there was a concern amongst those interviewed that this encourages short term arbitrage by some investors.


At the time of our report for AREF, there was a concern amongst those interviewed that this encourages short term arbitrage by some investors. On the face of it, this does not increase volatility since such investors are investing against the general flow of funds. However, it may encourage a short term attitude, although we did not identify any evidence of this in our work after the referendum.


At the time of our report for AREF, many intermediaries interviewed said that they have been reluctant to recommend investment in funds with two quoted prices (i.e. a fixed dual price model model) as they believe that this is confusing for retail investors. As a result, other fund managers have been reluctant to adopt this model due to the perceived lack of attractiveness to investors. Nevertheless, the fund mentioned in our report was successfully raising capital from those investors who believe that dual pricing is an appropriate model.




fReal estate is a complex asset class and there are many different possible fund structures and pricing models. It is therefore to be welcomed that there are two managers offering this pricing model, giving investors the choice of placing money with find managers who offer a traditional swinging price and now three offering a fixed dual price.


FCA discussion paper


On 29th May 2019, the FCA published a paper on swinging and dual pricing in open-ended funds with illiquid assets, "swing pricing and fragility in open-end mutual funds". You can find it here. It is one of the "occasional papers" published by the FCA to promote debate.


Although it refers to funds generally and mentions the suspension of property funds in the aftermath of the EU referendum, the analysis and conclusions are in respect of bond funds. Because of the cost of transacting property funds already use either swinging or dual pricing.


The paper is interesting for both property funds and debt funds in that it tacitly accepts a swinging price that is not directly based on the cost of transacting underlying investment assets.


The paper promises to be academic, and on this it delivers.


IOSCO on open-ended funds


The International Organization of Securities Commissions (IOSCO), the regulators' regulator has been taking a keen interest. As we have previously covered, in February 2018, it published two documents "Recommendations for Liquidity Risk Management for Collective Investment Schemes”   and "Open-ended Fund Liquidity and Risk Management – Good Practices and Issues for Consideration”.  You can read our comments on these from February 2018 here.

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