An Actively Managed Certificate (AMC) is a security that packages a professionally managed investment strategy into a single listed instrument, so the portfolio manager can adjust the underlying assets continuously without the investor trading anything. Legally it is a debt obligation of its issuer, not a fund, which makes the issuer's structure and collateralisation the central diligence question.
When a strategy is too specialised, too new or too small to justify a full fund launch, the AMC is the wrapper the industry reaches for. Understanding how it works tells you exactly what you own, what protects it, and what to check before subscribing.
How an AMC works
An issuer creates a certificate whose value tracks a reference portfolio. A portfolio manager, operating under a defined investment policy, adjusts that portfolio dynamically: equities, bonds, derivatives, commodities and other liquid assets can all be included. The investor holds one security with one ISIN; every rebalancing decision happens inside the wrapper.
The economics follow the strategy: the certificate's price reflects the reference portfolio's value net of fees, marked to market. Tradability is a different question, and it is worth being precise about it. An AMC admitted to trading can in principle be bought and sold during exchange hours, but in practice the price comes from a market maker's quote rather than from a book of other investors. Whether that amounts to usable liquidity depends on four things at once: which venue the instrument is admitted to and under what rules, whether a market maker is contractually obliged to quote and within what spread and size, how liquid the underlying assets themselves are, and what the issue terms say about suspension and early redemption. When the underlying stops trading, the quote is the first thing to widen or disappear.
AMC vs fund: the real trade-off
| Dimension | AMC | Investment fund |
|---|---|---|
| Asset protection | Issuer obligation; strong only if collateralised | Segregated fund assets by law |
| Launch time | Materially shorter — no product authorisation step | Longer — product authorisation and infrastructure |
| Cost base | Lower setup and running costs | Higher, full fund infrastructure |
| Strategy flexibility | Very high, incl. niche assets | Constrained by fund rules |
| Minimum viable size | Set by the fixed cost stack, quoted per deal | Higher — full fund infrastructure to amortise |
| Liquidity | Exchange hours if admitted and quoted — market-maker dependent | Dealing frequency set by fund rules |
This page previously quoted a typical launch time of two to three weeks and a minimum viable size of about EUR 1 million. Both figures have been removed. They circulate widely in the structured-products industry, but we could not attach either to a published methodology — no stated sample, no definition of what counts as “launch” or “viable”, no date — and an unsourced benchmark that a promoter may plan around is worse than no benchmark at all.
What can be said without a source is structural, and is more useful anyway. An AMC is faster than a fund principally because it issues under an existing base prospectus rather than seeking a product authorisation, so the timeline is driven by the issuer's onboarding and the drafting of final terms rather than by a regulator's review clock. Its minimum viable size is whatever makes the fixed costs tolerable as a percentage of assets: issuance and paying-agent fees, calculation agent, audit, market making and any listing fee. Ask a prospective issuer for that fixed cost stack in writing, then divide. The answer is specific to the deal, and any figure quoted without it is a marketing number.
The pattern in practice: managers prove a strategy in an AMC, then migrate it into a fund once assets and track record justify the heavier structure. For investors, that means AMCs are often where specialist strategies are accessible earliest.
Issuer risk, and how collateralisation contains it
The defining risk of any certificate is counterparty risk: if the issuer fails, holders are creditors. Two design choices determine how serious that is in practice.
Who the issuer is. A dedicated securitisation issuer that does nothing but issue collateralised instruments presents a different risk profile from a universal bank whose balance sheet carries unrelated businesses.
Whether the structure is collateralised. General rule Not every AMC is, and the three models differ materially: an unsecured note, a segregated reference portfolio that ring-fences assets to the series, and a secured structure that additionally pledges those assets to an independent security trustee who can enforce for that series' holders. Segregation tells you which pool your claim points at; a security interest tells you where you rank over it. Which model applies to a given certificate is stated in the issuer's base prospectus and the instrument's final terms, not in any summaryiMaps. This is the structure used for the instruments available through Framont Access, issued by iMaps ETI AG under a base prospectus approved by the Liechtenstein FMA.
The six risks, and where each one is actually documented
“Issuer risk” is the risk people name, and it is rarely the one that bites first. An AMC exposes a holder to six distinct risks that fail in different ways and are disclosed in different documents:
| Risk | What goes wrong | Where it is documented |
|---|---|---|
| Issuer | The issuer cannot pay and you rank as a creditor | Base prospectus — issuer description, financials |
| Collateral | Assets are not segregated or not pledged, or enforcement is slow, partial or contested | Base prospectus — security provisions; final terms |
| Strategy | The investment policy permits more concentration, leverage or drift than you assumed | Final terms — investment policy and limits |
| Liquidity | No firm quote when you need one, or a spread that swallows the return | Final terms and the venue's market-making rules |
| Valuation | The reference portfolio holds assets whose price is modelled rather than observed | Base prospectus — valuation and calculation agent provisions |
| Operational | Calculation agent, paying agent or custodian failure; corporate actions mishandled | Base prospectus — agent roles and substitution provisions |
Note The matrix is an editorial framework. What each document must contain is set by Regulation (EU) 2017/1129 for the prospectus and final termsEUR-Lex and, where a KID exists, by Regulation (EU) No 1286/2014EUR-Lex. Note that a professional-only AMC will not have a KID at all.
Who does what: reading the roles correctly
AMC documentation names several parties, and the distinctions matter for diligence:
- Strategy developer: designs the underlying strategy and supplies its signals or model. Not a custodian of investor money.
- Portfolio manager: the regulated entity executing the strategy inside the wrapper. For Framont Access instruments this is Framont & Partners Management Ltd, an AIFM authorised by the MFSA in Malta.
- Issuer: creates the security and maintains the segregated portfolio.
- Market maker: quotes tradable prices on the exchange.
- Security trustee: holds the collateral pledge for investors.
A clean structure separates these roles. If one entity plays all of them with no independent trustee, the protections are weaker than the marketing may suggest.
Framont example Where a certificate on this platform is reserved to professional investors — clients meeting the MiFID II Annex II criteriaEUR-Lex — it publishes a term sheet rather than a KID. The portfolio manager's authorisation can be confirmed independently in the MFSA Financial Services RegisterMFSA.
Costs to expect
AMCs typically carry a management fee accrued daily in the certificate price, and often a performance fee calculated above a high-water mark, meaning the manager earns it only on net new highs. Some instruments add entry or exit fees. Every fee must be disclosed in the KID's cost tables, expressed both as a percentage and in money terms over the recommended holding period. Compare KIDs, not brochures.
Frequently asked questions
Is an AMC a fund?
Why choose an AMC over launching a fund?
How liquid is an AMC?
What fees does an AMC carry?
AMC products are now live on Framont Access. Explore the AMC shelf, or view the Exchange Traded Instruments, which use the same collateralised issuance structure.