Unit Pricing Policy Template – Unregistered Managed Investment Schemes (AFSL)
Aligned with ASIC & APRA RG 94
$299.00 +GST
- Document the formulas and methods used to calculate unit prices;
- Set out each pricing discretion and when it may be exercised;
- Record valuation methods for hedge, direct property and mortgage funds;
- Assign policy ownership, board approval and annual review responsibilities.
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About this Document
This Unit Pricing Policy Template gives a fund operator a documented basis for calculating unit prices across the schemes it operates. It is written for an AFSL holder acting as trustee and/or investment manager of unregistered managed investment schemes, and it states expressly that the entity does not act, and does not intend to act, in the capacity of a Responsible Entity.
Use this policy if you:
- Operate or manage one or more unitised managed investment schemes
- Act as trustee of unregistered schemes rather than as a Responsible Entity
- Need a documented method for current unit value, issue and withdrawal prices
- Exercise discretion over valuations, buy/sell spreads or pricing frequency
- Want your unit pricing practices aligned with RG 94 good practice principles
It is suited to:
- AFSL holders operating unregistered managed investment schemes
- Trustees and investment managers of unitised funds
- Compliance officers responsible for unit pricing oversight
- Boards and investment committees approving pricing methodology
What this policy covers:
- Net asset value, gross asset value and the treatment of liabilities under AIFRS
- Issue (application) and withdrawal (redemption) price formulas
- Six discretions that may affect the unit price
- Valuation methods for hedge funds, direct property funds and mortgage funds
- Transaction charges and the buy/sell spread rationale
- Frequency, suspension and rounding of unit prices
- Deviation from the policy, with seven-year retention of discretion records
- Compliance Officer monitoring, error investigation and investor compensation
You receive an editable Word document with placeholders for your entity name, ACN and the date the board approves the policy, alongside an approvals and version history table, a key obligations table and a full definitions list. Schedule 1 is supplied with a worked example row already completed, covering capacity, the NAV and GAV formulas, a buy/sell spread of up to 0.30%, pricing each business day and rounding to four decimal places, so you have a model to follow for each of your own funds. Tailor it to your governing documents, disclosure documents and licence conditions, and take advice on your own circumstances before adopting it.
How To Use This Template
This template is a starting point, not a final document. It’s been drafted by Australian lawyers to be practical and flexible, but it still needs to be reviewed and tailored for your specific business, transaction and risk profile.
Before you use it, you should:
- Complete all placeholders, bracketed items and optional fields;
- Remove any drafting notes or clauses that aren’t relevant to your situation; and
- Check that party names, entity details, dates, addresses, contact details and defined terms are accurate.
Make sure the template is consistent with your other documents and obligations – including any existing contracts, policies, procedures, website terms, privacy disclosures, regulatory requirements or internal governance documents. If anything conflicts, it should be resolved before you sign, issue, adopt or implement the document.
If you are using the template as an agreement, it should be reviewed and signed by all relevant parties in accordance with applicable law and your internal signing requirements. If you are using it as a policy, procedure, notice or compliance record, it should be approved and stored under your organisation’s normal document control processes.
This template is provided as general information only and is not legal advice. Complex, high‑value, highly regulated or cross‑border matters will usually require bespoke drafting. For anything outside a straightforward use case, we strongly recommend obtaining legal advice before relying on, signing or implementing this document.
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