Summary of SPOT Inspections on Communications to Clients in Relation to SCPIs (Autorite des marches financiers)

Summary

• The AMF conducted a thematic SPOT inspection campaign across 4 investment services providers regarding client communications for SCPI real estate products.p.1
• The inspections evaluated institution practices over the period from 1 January 2022 to the first half of 2026, using July 2023 as a turning point.p.1
• From the second half of 2023 onwards, the commercial SCPI market experienced marked deterioration, longer redemption periods, and unit price drops.p.1
• Suitability reports frequently lacked explanations as to why illiquid or devalued SCPIs remained suitable investment opportunities for clients.p.2
• Inspected entities displayed poor practices such as lacking formal criteria to trigger offering revisions and failing to limit SCPI exposure relative to client savings.p.2
• Observed good practices included delisting certain SCPIs based on changing product characteristics and offering educational tools to sales networks.p.3

Key insights

1. Non-compliance issues identified prior to July 2023 persisted after that date because institutions failed to adapt their oversight systems as risks materialised.p.2
2. Suitability reports often relied on standardized rationales that failed to reflect individual SCPI changes or specific client situations.p.2
3. Several providers could not verify whether clients actually received marketing materials or identify which version was active at subscription.p.2
4. Institutions failed to put safeguards in place to restrict client financial exposure to illiquid SCPIs relative to total savings.p.3
5. Restricting SCPI distribution exclusively to investment advice services was recognized as an effective good practice.p.3
6. Leading providers proactively communicated significant changes directly to existing unitholders when ongoing advice fees were not received.p.3