“Investments in Bricks and Mortar” – the FMA informs about investment products with real estate links

While not a new rule, it signals heightened supervisory attention to how these products are described and sold. For compliance teams, the key is to test whether marketing and disclosures clearly explain exposure to property markets, valuation uncertainty, liquidity constraints, leverage and concentration risk. Firms distributing or advising on such products should review product governance, target-market assessments and suitability processes, and ensure that risk warnings are prominent and not diluted by yield-focused messaging.

Crowdfunding and bond structures warrant particular scrutiny where investors may not have direct ownership of underlying property. No immediate filing or reporting obligation arises, but firms should document their review and be ready to respond to supervisory questions. RegCanary recommends a focused sweep of real estate-linked product materials and adviser training, plus monitoring for follow-up FMA guidance.