Redemption of SCPI units: where should incomplete requests be entered in the chronological register?
Holders of units in variable-capital real estate investment companies (SCPIs) who wish to redeem their units, i.e. sell them to a third party, must submit a request to this effect to the SCPI's investment management company. The latter then enters their request in a register and assigns them a rank. The total or partial redemption of a member’s units is carried out according to this rank, i.e. in chronological order of entry in the register. Execution of the requests is subject to there being sufficient demand for subscriptions to match the redemptions requested.
Holders of SCPI units may find that their rank in the register of redemption orders has slipped. For retail investors who have been waiting, sometimes for a long time, for their redemption request to be executed, such developments are difficult to understand.
This month's dossier describes the experience of one of them, in which I noted a change in the practice of a professional, who clarified and improved how the register works in this respect.
Facts
Mr X holds units in an variable-capital SCPI, which he requested to redeem on 18 March 2025. Using the investment management company's quarterly newsletters for March and June 2025, Mr X calculated that a maximum of 43,900 units preceded his own in the order register.
However, in August 2025, he was informed by the investment management company that 52,000 units had to be served before his own.
Mr X questioned the investment management company about this drop in his position in the order register.
The investment management company replied that all redemption requests were entered in the register in chronological order of receipt, but that some of them, entered before his own, required additional information from the unitholders concerned before they could be executed. In accordance with its practice at the time, the investment management company did not initially include these requests in the number of units pending redemption it published. However, the requests for which the expected additional information was subsequently provided were reintegrated into the figures published for the volume of units pending redemption, retaining their registration date.
Mr X felt that this procedure was not transparent and that it resulted in the inequitable treatment of unitholders. Incomplete requests can thus be rectified at the discretion of the unitholder, without any time limit, while retaining the initial registration date, to the detriment of 'exemplary' holders whose requests were complete from the outset.
It was in these circumstances that Mr X asked me to intervene.
Investigation
I questioned the investment management company, which confirmed that, pursuant to Article 1114 of the Civil Code and in application of Article 422-218 of the AMF General Regulation, as soon as it receives a request, it makes an entry in the redemption order register, stating the name of the unitholder, the name of the designated SCPI, and the number and price of the units for which redemption is requested.
However, the investment management company frequently needs additional documents or information, as set out in the offering document or the SCPI’s articles of incorporation. If the request is incomplete, it is registered, but is classified as “not executable”. It only becomes executable on receipt of these documents. As it is impossible to predict whether and how soon a file will be completed, in its quarterly newsletters the investment management company only communicates the information that, in its opinion, is reliable: the number of registered and complete requests in the redemption order register, i.e. those that are actually pending execution.
Based on informal exchanges on this issue between the AMF and the Association Française des Sociétés de Placement Immobilier (ASPIM), and on discussions within the latter, the investment management company considered it possible, in the second half of 2025, to set a maximum time limit for members to complete a unit redemption request, failing which they would lose their ranking in the register.
The investment management company has therefore decided to change its procedure and has announced, in its quarterly newsletter and in the SCPI's documentation, that any incomplete redemption request will henceforth have to be rectified within thirty days of receipt in order to retain its entry ranking in the register; after this deadline has elapsed, the ranking in the register will be changed to that corresponding to the date of receipt of the necessary supporting documents.
Recommendation
On receiving this reply and after a careful analysis of the case, I reminded the retail investor that Article 422-218 of the AMF General Regulation, applicable to variable-capital SCPIs, allows the investment management company to change the conditions for submitting a redemption request in its offering document or the SCPI’s articles of incorporation, particularly with regard to the documents to be provided.
In some cases, although the redemption form complies with the requirements of the Civil Code in terms of the information necessary to create a contract, certain administrative documents are missing (for example, the unitholder's bank details, proof of address, or even a certificate of ownership if the units were acquired by inheritance). In this case, the redemption request is still entered in the redemption register on the day the form is received, but cannot be executed until the missing documents have been provided. In the case in question, Mr X's complete redemption request was entered in the redemption register as soon as his request was received by the investment management company, i.e. on 18 March 2025. I explained this process to him and pointed out that no redemption request sent after that date had skipped ahead of the registration rank of his request. The apparent drop in rank in August 2025 was due solely to the regularisation of redemption requests received and registered before 18 March 2025.
I also informed him that the investment management company had implemented the change described above, so that the ranking of his redemption request would now only progress, as and when the redemption requests prior to his request were executed, in chronological order.
Lesson to be learned
In order to comply with the provisions of the Monetary and Financial Code and the AMF General Regulation, and in particular the requirements relating to know-your-customer and anti-money laundering, the investment management company of an SCPI must request various pieces of information or documents from unitholders who wish to redeem their units.
In order to ensure that unitholders are fully informed about the procedures for exiting their investment, the investment management company must set out, in the SCPI's documentation, the minimum information that a redemption request must contain in order to be entered in the register and the exhaustive list of documents that must be provided in order for the request to be executed.
Where applicable, it must also indicate the time allowed for the requesting person to complete their file if any documents are missing, and the consequences of failing to meet this deadline.
From the various Mediation cases, it seems to me that at least one other investment management company has taken the initiative of setting up such a procedure for regularising redemption requests. This seems to me to be a step in the right direction in terms of improving the process for handling redemption requests and ensuring greater fairness between the unitholders concerned, and I can but encourage this practice.
