In a mediator blog post on a complaint involving a variable-capital SCPI, the French Financial Markets Authority clarified how incomplete withdrawal requests are treated in the chronological withdrawal register. A request that contains the minimum elements required to form the transaction can be entered on receipt, but it remains non-executable until the missing administrative documents are provided. The post also reports that the management company involved has revised its process so that an incomplete request must now be completed within 30 days of receipt to retain its original rank, otherwise its position shifts to the date the outstanding documents are received. The case arose after an investor who filed a withdrawal request on 18 March 2025 saw the number of units ahead of him rise from a maximum of 43,900 based on quarterly disclosures to 52,000 in August 2025. The management company explained that some earlier requests had initially been excluded from the published backlog because they were incomplete, then reinstated with their original registration dates once regularised. The mediator said this apparent worsening in rank did not mean later requests had overtaken the investor. Citing Article 422-218 of the AMF General Regulation, the post adds that management companies may set submission conditions in SCPI documentation and should clearly disclose the minimum information needed for registration, the full list of documents required for executability, and any deadline and consequence for curing an incomplete file.
France Autorite des marches financiers2026-05-18
French Financial Markets Authority mediator clarifies handling of incomplete SCPI withdrawal requests and highlights 30 day deadline to keep register rank
The French Financial Markets Authority, via a mediator blog post on a variable-capital SCPI complaint, clarified that withdrawal requests with minimum required elements may be recorded in the chronological register on receipt but remain non-executable until all documents are provided. The management company concerned now requires incomplete requests to be completed within 30 days to retain their original rank, otherwise they are re-dated to when missing documents are received. Referring to Article 422-218 of the AMF General Regulation, the post stresses that SCPI documentation should clearly set out minimum information for registration, required documents for execution, and any deadlines and consequences for curing incomplete files.