Who holds your KiwiSaver money?
Four different jobs sit behind every KiwiSaver scheme, and they are usually done by three or four different companies. One holds the licence. One picks the investments. One independently watches the first. One physically holds the money.
They are separate on purpose. The company that decides what your fund buys is not the company holding what it bought, and the company supervising both answers to you rather than to them. Each role is defined in Part 4 of the Financial Markets Conduct Act 2013, and the section numbers below are linked so you can read the duty rather than take our description of it.
Manager
Holds the FMA licence for the scheme and is legally responsible for it.
The manager offers the scheme, issues the interests, and carries the management and administration functions. On a multi-manager scheme this is often a company you have never heard of, because its job is to hold the licence and run the scheme rather than to pick investments.
- s142 Management and administration functions of manager
- s143 General duties applying in exercise of manager's functions
- s145 Duties of directors and senior managers of manager
- s147 Duty of manager to provide reports to supervisor or FMA
Investment manager
Chooses what the fund actually buys — where one is engaged.
A manager can contract out management functions, and where it does, the Act names the investment manager separately and holds it to the same standard of care. This is why a fund can carry a well-known investment brand while a different company holds the licence: the brand is often the investment manager, not the manager of the scheme.
- s144 Duty of manager and investment manager to comply with relevant professional standard of care
- s146 Contracting out of management functions
Supervisor
Independent, separately licensed, and there to watch the manager on your behalf.
The supervisor supervises the manager’s performance of its functions and its financial position, and it must act in the interests of scheme participants. It is licensed separately from the manager and is a different company. It can engage its own experts to do the job.
- s152 Functions of supervisor
- s153 General duties applying in exercise of supervisor's functions
- s154 Duty of supervisor to comply with professional standard of care
- s155 Power of supervisor to engage expert
Custodian
Physically holds the scheme property, on trust, separately from the manager.
The scheme must have a custodian, and it must be the supervisor or another independent person — not the manager. The custodian holds the property on trust for the scheme, must keep records of it, and must report on it. This is the provision that keeps your money legally separate from the balance sheet of the company managing it.
- s156 Requirement to have supervisor or other independent person as custodian
- s157 Custodian holds scheme property on trust
- s158 Custodian must keep records of scheme property
- s159 Custodian must report on scheme property
Why the name on your fund is often not the licence holder
Section 146 lets a manager contract out its management functions, and section 144 then names the investment manager separately and holds it to the same standard of care. That is the legal basis for a multi-manager scheme: one company holds the licence and runs the scheme, while several well-known investment firms run the money inside it.
So a fund whose name carries a familiar investment brand may sit inside a scheme whose licensed manager is a company most members have never heard of. Neither fact is hidden: both are named in the scheme documents on the Disclose register. They are simply different roles, and reading one as the other is the most common mistake made about this structure.
How to check yours
Every scheme’s Product Disclosure Statement and Statement of Investment Policy and Objectives names its manager, supervisor and custodian, and both documents are lodged publicly on the FMA Disclose register. Search your scheme, open the current PDS, and the parties are named in the front section.
A note on our own data. Where we show these parties elsewhere on the site, they are read from the PDS text, and we fail closed: if a document does not name a party, we record nothing rather than infer one. A blank means “this PDS does not name it” — never that the scheme has none, which for a supervisor is not possible. Many PDSs genuinely decline to name a custodian, saying only that the supervisor or an appointed custodian holds the assets, so blanks are common and correct. Treat the register document as the answer and anything derived from it, here or elsewhere, as a pointer to it.
General information about how the regime works, not financial advice, and not a statement about any particular scheme. For how managed investment schemes are structured more broadly, see the managed investment scheme guide on ManagedFundsNZ.
Compare every fund on the FMA Disclose register. Refreshed quarterly. Independent — FundCompare is not a Financial Advice Provider; general information only.
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