Running a wholesale managed investment scheme means a trustee, scheme operation and fund administration — each with its own licensing and operational requirements. Provenance provides that infrastructure on the licensed framework of Providence Equity Holdings, so you can establish and run a wholesale fund without standing up the trustee and operational stack yourself.
Registered vs unregistered schemes
Whether a managed investment scheme must be registered with ASIC turns largely on who invests in it — and Provenance's infrastructure is built for unregistered wholesale schemes.
| Registered scheme | Unregistered (wholesale) scheme | |
|---|---|---|
| Who can invest | Retail investors (broadly, a scheme with more than 20 members and a promoter in the business of promoting schemes). | Offered only to wholesale clients. |
| Registration with ASIC | Registered with ASIC. | Generally does not need to be registered (the s 601ED(2) wholesale exemption). |
| Responsible entity / operator | Needs a responsible entity: a public company holding an AFSL to operate the registered scheme, with significant capital and governance requirements. | No responsible entity required; the operator and trustee still need AFSL authorisation — which is what we provide. |
| Product disclosure statement | PDS required. | No product disclosure statement. |
New to scheme structures? See our guide to the licensing pathways.
What we provide
The trustee and operational stack for a wholesale scheme:
- Trustee — acting as, or providing, the licensed trustee of the wholesale scheme.
- Scheme operation — operating the scheme under AFSL authorisation.
- Fund administration — unit registry, applications and redemptions, unit pricing / NAV, distributions and investor reporting.
- Establishment — the trust deed / constitution and vehicle setup.
How it works with Provenance
- Trustee / infrastructure model — Providence provides the trustee and scheme infrastructure for your wholesale vehicle, used alongside your own licence or authorisation.
- Authorised representative model — Providence remains trustee, issuer and operator of the scheme, while you're onboarded as an authorised representative under our licence to run the investment strategy and provide dealing and advising in relation to it. A corporate authorised representative cannot itself operate the scheme. → Authorised Representative Onboarding
- Vehicle options — wholesale unit trust (most common), SPV, or limited partnership.
This is the infrastructure behind pooled deals: if you're syndicating or co-investing with other wholesale investors, this is the engine that vehicle runs on. → Syndication & Co-Investment
What's included
- Trustee and issuer of the scheme
- Scheme operation — Providence acts as operator
- Fund administration
- Establishment as set out above
Your responsibilities
Who it's for
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Syndication & Co-Investment →
Licensed infrastructure to pool wholesale capital into deals.
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Family Offices →
Co-invest with peers and lead your own deals under licensed infrastructure.
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Investment Managers →
Launch or relocate a wholesale strategy under an established AFSL.
Frequently asked questions
Do I need to register my scheme?
Generally not, if it's offered only to wholesale clients — the wholesale exemption means no registration and no responsible entity (s 601ED(2)). If retail investors are involved, registration and a responsible entity are required, which is outside our wholesale infrastructure.
Do I need my own AFSL to operate a wholesale scheme?
The operator and trustee need AFSL authorisation, but that doesn't have to be yours. Providence acts as trustee, issuer and operator of the scheme, while you're onboarded as an authorised representative under our licence to run the investment strategy and provide dealing and advising in relation to it. A corporate authorised representative cannot itself operate a managed investment scheme — that role sits with the licensee.
Who holds the scheme's assets?
Provenance does not provide standalone custodial services to third parties. Where Provenance operates a wholesale scheme, the scheme's assets may be held by Provenance on an incidental basis — incidental custody, consistent with ASIC's custody requirements (RG 133) — or by a separately appointed custodian.
Is this an offer to invest in a fund?
No. We provide the licensed trustee and scheme infrastructure you operate on. We don't offer or recommend interests in any scheme.
Is this only for wholesale clients?
Yes — Provenance's infrastructure is for wholesale schemes and wholesale clients only.