Japan's Financial Services Agency has finalized a new line item in the checklist supervisors use on investment-trust managers: whether they set redemption terms and other tools that actually match how easily their underlying assets can be sold. The addition, item twelve under the guideline's business-execution section for fund managers, asks supervisors to check for "reasonable measures" on liquidity, citing redemption conditions calibrated to asset liquidity and the introduction of a variable trust-property reserve. The FSA traces the change to a May 2025 IOSCO recommendation on liquidity-risk management for collective investment schemes.
During the FSA's public consultation, held from May 8 to June 8, 2026, one commenter flagged that the draft never explicitly said the new item covered publicly offered investment trusts rather than private ones. The FSA agreed and said it would revise the wording to make that scope explicit.
A second commenter pushed harder, arguing the revision only tightens compliance procedures at large financial institutions without addressing high fees or the structure by which retail investors' returns get absorbed by product providers. The FSA's written reply thanked the commenter for a "valuable opinion" without committing to any further change.
The new item is evaluative, not a bright-line rule. The guideline notes that missing one item alone does not automatically make a manager's practices inappropriate; supervisors weigh the scope and scale of its business as a whole. The revised guideline takes effect on October 1, 2027.