Distribution Defined Under CISA

Article 3.1 of CISA and Article 3 of CISO define distribution as any activity whose purpose is the purchase of units of collective investment schemes.

Distribution is also defined as any offering or advertising for collective investment schemes including but not limited to :

  • Meetings with financial intermediaries of any kind
  • Emails containing information on collective investments schemes
  • Presentations and road shows
  • Unsolicited phone calls (cold calling)
  • Sponsored reports on collective investment schemes
  • Participating in trade shows geared to finance
  • Telemarketing
  • Websites and other forms of e-commerce. Online subscription opportunities
  • Offering or advertisement regarding managed accounts whose underlying investments are collective investment schemes

 

The following activities are not considered to be “Distribution” by CISA and CISO : 

  • Genuine and documented reverse solicitation
  • Any of the above activities made by an investment manager to investors under written discretionary management agreement or by investment advisors to investors under investment advisory agreement