2026-01-26

Corporate Trustees Reporting Template

This circular mandates that all licensed corporate trustees submit quarterly compliance reports to the Capital Markets Authority within twenty-one days of the quarter's end. The attached reporting template requires trustees to document key highlights, asset reconciliations between custodians and fund managers, and details of any non-compliance incidents. Furthermore, trustees must provide disclosures regarding advertisements, conflicts of interest, amendments to incorporation documents, early warning signs, and a formal declaration of oversight verification.

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Capital Markets Authority Kenya

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Circular No. 02/2026

January 26, 2026

To: All Licensed Corporate Trustees

RE: TRUSTEE REPORTING TEMPLATE

Part V Division A of the Capital Markets (Collective Investment Schemes) Regulations, 2023 provides for the appointment and responsibilities of a Trustee by a Collective Investment Scheme (CIS). This is aimed at ensuring that fiduciary obligations and the principle of stewardship are consistently upheld to protect and benefit the unit holders.

Regulation 42(2) of the Collective Investments Schemes Regulations, 2023 provides that a trustee shall submit to the Authority within twenty-one days after the end of each quarter, the compliance status of the scheme in accordance with these Regulations.

Kindly find attached the Trustee reporting template, which outlines the information to be included in the quarterly report.

Yours sincerely,

FCPA Wycliffe Shamiah MBS CHIEF EXECUTIVE OFFICER

TRUSTEE REPORTING TEMPLATE

1. KEY HIGHLIGHTS

The Trustee to provide a summary of observations and key developments, and on any other significant/relevant information or event(s) noted during the quarter regarding the funds under trusteeship.

2. RECONCILIATION REPORT

The trustee to report on Reconciliation of assets under management taking into account reports of the Custodian and Fund Manager of each CIS, in line with Regulation 42 (1) of the Capital Markets (Collective Investment Schemes) Regulations, 2023 (the CIS Regulations), in the format provided in Table 1 below.

3. REPORTING ON NON-COMPLIANCES

The trustee shall report on incidences of non-compliance relating to the different CIS under their oversight. The information should be presented in tabular format.

4. ADVERTISEMENTS

Trustee to provide a list of all adverts approved by the Trustee during the quarter.

5. CONFLICT OF INTEREST DISCLOSURES

Trustee to report on any conflicts disclosed by or relating to the fund, Fund Manager, or Custodian during the quarter in line with Regulation 45(1) of the CIS Regulations.

6. CHANGES TO THE INCORPORATION DOCUMENTS

Trustee to report on any amendments to the Incorporation documents of the fund(s) during the quarter.

7. EARLY WARNING SIGNS

Trustee to report on any early warning signs noted during the quarter, if any.

8. DECLARATION

We confirm that, to the best of our knowledge and belief, and based on the Trustee's independent oversight, review, and verification undertaken during the reporting period: (a) The assets of the scheme exist and are properly accounted for; (b) The assets are properly titled; (c) The Custodian holds all scheme assets in trust for the benefit of the unit holders; and (d) Except as disclosed in this report, the Trustee is not aware of any material breaches of the CIS Regulations, or the Trust Deed that remain unresolved as at the end of the reporting period.