1.2 Investment-Linked Funds Are Not UTS; Industry Growth and History

Key Takeaways

  • Investment-linked funds of life insurers are not monitored by a Trustee, are not scrutinised by the SC and fall under the purview of Bank Negara Malaysia.

  • In an investment-linked fund, premiums less the cost of life cover and entry fees are invested in the insurer's investment pools at the pool's unit selling price.

  • Malaysia's first unit trust was set up in 1959 by Malayan Unit Trust Limited, and the Capital Issues Committee issued the first Guidelines on Unit Trust Funds in 1991.

  • The SC, established in 1993, became the sole regulator of collective investment schemes in 1996.

  • PRS was introduced in Malaysia in 2012 as the voluntary third pillar of a multi-pillar pension framework.

Last updated: October 2026

Why This Comparison Is Tested

Consultants often meet investors who hold, or are being offered, an investment-linked insurance policy. FIMM wants Consultants to understand that these products look similar to UTS but are legally and regulatorily different, and to explain that difference.

How an Investment-Linked Fund Works

The study guide describes the mechanics as follows:

  1. The policyholder buys a life insurance policy that represents a number of units in an investment pool managed by the life insurer.
  2. The policy can be bought with a single premium (like a lump sum) or regular premiums (like a unit trust regular savings plan).
  3. Premiums less the cost of life cover and entry fees are allocated, at the policyholder's direction, to one or more investment pools, each with its own objective.
  4. Each pool is divided into equal units. A policy's value is units held × unit price.
  5. Units have a buy price and a sell price: net premiums buy units at the pool's selling price, and on surrender units are cashed in at the pool's buying price.
  6. Investment management fees and other charges are deducted from the pool.
  7. Pool returns are taxed at the life insurer's rate, and a provision for tax on unrealised gains is deducted before unit prices are set.

The most important sentence for the exam: investment-linked funds are not monitored by a Trustee, are not scrutinised by the SC and are not subject to the SC's disclosure rules. They fall under Bank Negara Malaysia (BNM). Investors must be told about this difference.

FeatureUTSInvestment-linked fund
NaturePure collective investmentLife insurance policy with investment units
SupervisorSecurities Commission MalaysiaBank Negara Malaysia
TrusteeYes, independent scheme trusteeNo scheme trustee
Disclosure rulesSC prospectus and Product Highlights Sheet (PHS) rulesBNM insurance rules
Life coverNoneIncluded; cost deducted from premiums
Unit pricingSingle NAV-based priceSeparate buy and sell prices
SellerFIMM-registered ConsultantLicensed insurance agent

FIMM's own practice question asks whether investment-linked funds that invest in capital market products must comply with the SC's regulations. The answer is false: they follow BNM's rules.

Size and Growth of the Industry

The study guide makes three points:

  • Fund management has been the fastest-growing part of Malaysia's capital market over the last decade.
  • UTS and wholesale funds have been the main drivers of that growth.
  • The introduction of PRS added another option for investors saving for retirement.

The SC publishes up-to-date statistics on fund size and sources of funds on its "fund management products" analytics page. The FCE does not expect you to memorise current ringgit totals, which change constantly.

Milestones in the Development of CIS

YearMilestone
1868The world's first unit trust, The Foreign and Colonial Government Trust, is set up in London
1950sOpen-end investment companies (mutual funds) become popular in the United States
1959Malaysia's first unit trust is established by Malayan Unit Trust Limited
1960s–1970sUnit trusts grow in popularity in the UK and Australia
1991The Capital Issues Committee issues the Guidelines on Unit Trust Funds, the first CIS regulation in Malaysia
1993The SC is established; UTS are jointly regulated by the SC and the Registrar of Companies
1996The SC becomes the sole regulator of CIS
2012PRS is introduced as the voluntary third pillar of retirement saving

Malaysia introduced unit trusts early compared with its neighbours, yet there was no regulation until 1991. After 1996 the focus was on developing UTS so that retail investors could take part in the stock market through professionally managed funds. In the 1990s many retail investors traded on rumours, which added to market volatility. Pooling their money under professional managers, and raising the share of institutional investors who could push for good corporate governance, were seen as ways to reduce that volatility.

PRS arrived in 2012 to tackle the adequacy of retirement savings as the population ages. It complements the mandatory EPF scheme and forms the third pillar of the World Bank's multi-pillar pension framework (Chapter 7B).

The Islamic Capital Market

The study guide also highlights the Islamic capital market (ICM), a segment of the wider capital market that complements Islamic banking, takaful and the Islamic money market. The SC has developed the ICM on two fronts:

  1. building the supporting infrastructure; and
  2. widening the range of Islamic products.

The ICM's growth has broadened the capital market and the financial services industry generally. Shariah-compliant UTS and PRS are covered in Chapter 2 and Chapter 7A of this guide.

Test Your Knowledge

An investor asks whether the investment-linked fund in her life policy is supervised in the same way as a unit trust. Which answer is correct?

A

Yes, but only investment-linked funds that invest in Malaysian shares

B

No, investment-linked funds are supervised by FIMM instead of the SC

C

No, investment-linked funds fall under Bank Negara Malaysia and have no scheme trustee or SC disclosure regime

D

Yes, both are scrutinised by the SC and monitored by an independent scheme trustee

Test Your Knowledge

Which body issued Malaysia's first Guidelines on Unit Trust Funds in 1991?

A

The Capital Issues Committee

B

Bank Negara Malaysia

C

The Securities Commission Malaysia

D

The Federation of Investment Managers Malaysia

Test Your Knowledge

In which year did the Securities Commission Malaysia become the sole regulator of collective investment schemes?

A

1991

B

2012

C

1993

D

1996

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