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Why a global ETF is delisting from the LSE (and what happens next)

Why a global ETF is delisting from the LSE (and what happens next) post image

The Amundi Prime Global ETF (PRWU / PR1W) is delisting from the London Stock Exchange (LSE).

Though the ETF will continue life on Germany’s Xetra exchange, you can’t own that version in an ISA.

You can own it in a taxable account. But that will have serious tax implications if Amundi does not gain UK reporting fund status for the Xetra incarnation of the ETF.

Moreover, affected investors are being given just a few weeks’ notice to make consequential decisions, and with scant and confusing information.

Potential issues raised by PRWU owners include:

  • Triggering a capital gains tax event if you decide to sell the ETF from a General Investment Account (GIA).
  • Not having time to sell PRWU held within an ISA should you miss the relevant communications from your broker, or if you’re acting as the executor of a will.
  • Confusion about whether the transfer of the ETF from a Lifetime ISA causes a withdrawal penalty on the government bonus.
  • Potentially not being able to sell their ETF for months afterwards if they miss the deadline to sell prior to the delisting event, judging by reports from investors caught up in a previous delisting.

Delisting drama

So why is this happening and what are the rules if it happens to you?

Before continuing, I’d like to thank Monevator readers Peter Rabbit and J. They raised the alarm with helpful comments on Monevator’s low-cost trackers page and via email.

Also, let’s be clear that neither an ETF delisting nor closure means you’ll lose your money, in case you’re worried about that.

The main consequences are:

  • Potentially making a loss if you’re sold to cash and end up being out of the market for a time.
  • Not being able to access your money for a while if your broker handles the situation badly.
  • Being forced into a capital gains event. (Though I think there’s reason to believe that Amundi will reacquire UK reporting tax status for the ETF. I’ll explain why below.)
  • Loss of some ISA benefits if sale or redemption isn’t made in time.

Why is the Amundi Prime Global ETF delisting?

In brief, Amundi is moving the ETF’s domicile from Luxembourg to Ireland.

That’s good news for most investors because they’ll pay less withholding tax on the fund’s US securities due to Ireland’s superior tax treaty with the States.

But it’s bad news for UK investors, thanks to our old friend Brexit.

Prior to Brexit, fund firms could distribute their products across European Economic Area (EEA) borders using common passporting rules.

It was easy. No need to delist your ETF from the LSE.

Then, as Brexit approached like a small moon, the FCA invented the Temporary Marketing Permissions Regime (TMPR) to enable business to carry on.

However, TMPR does not cover new financial products registered with the FCA since 30 December 2020.

Want to promote your new EEA domiciled fund in the UK today? Then recognition is yours via the alternative Overseas Fund Regime (OFR).

But alas, the OFR only began accepting applications from 30 September 2024.

In between times, fund providers had to resort to the UK’s ‘Section 272’ recognition process. This choice piece of bureaucracy has been described variously as ‘cost intensive’, ‘time consuming’, and ‘legally expensive’.

Numerous articles quote industry insiders referring to Section 272’s bad reputation and its deterrent effect upon companies wishing to launch new funds in the UK.

Nice work Global Britain!

The OFR is supposed to be a much easier and less expensive route to market. Though still not as cheap and effective as the old passporting regime.

Amundi-ng its own business

Amundi Prime Global’s OFR application is apparently underway. But not in time to enable the Irish version of the ETF to be LSE-listed before the Luxembourg sub-fund disappears.

And apparently Amundi wasn’t minded to hang around on behalf of its UK investors.

Assuming the ETF regains UK recognition, then this ETF will be back on the LSE at some point. But Amundi pushed ahead with the nuclear option anyway, announcing the delisting on 16 October 2024 and giving investors until 15 November to decide if they wish to redeem their shares via the fund manager.

And this timeline was shortened for those investors who report first hearing about the delisting from their brokers some days later.

The impact of delisting on investors

I personally think ISA owners are best off selling the ETF while they’re still in full control of the situation.

The rules on non-qualifying investments1 in a stocks and shares ISA say:

Where the new investments are not qualifying investments, managers must, within 30 calendar days of the date on which they became non-qualifying investments, either:

– sell them (in which case the proceeds can remain in the stocks and shares ISA)

– transfer them to the investor to be held outside the ISA.

LISA qualifying investment rules are the same as for stocks and shares ISAs.

I can’t find out if a broker transferring non-qualifying investments from a LISA would incur a withdrawal charge designed to negate the government bonus.

But that seems probable, otherwise news of the “AWESOME LISA hack you MUST TRY” would probably have gone viral by now.

Meanwhile, there’s quite a bit of guidance out there advising that if delisted shares (remember: ETFs count as shares) are transferred outside of your ISA, then you can’t replace that money without reducing your annual allowance.

In other words, you should sell the ETF while it still resides within your tax shelter.

The consensus view is that your holding’s market value on the date of transfer is your base cost for future capital gains calculations. So you can’t carry over a capital loss from your ISA, but neither should you be stuck with an immediate capital gain.

However, HMRC’s ISA pages are silent on the issue. Or at least I haven’t been able to find the answer within.

And I’d rather not rely on whatever a random broker’s agent or HMRC forum denizen claims that day.

De-list of To Dos

All of which leads me to conclude that the safest course of action is to sell while you can. All other priorities are rescinded.

Once you sell you can then immediately reinvest the proceeds into another LSE-listed ETF that replaces Amundi Prime Global in your line-up. There are plenty to choose from.

I wouldn’t worry about other retail investors doing the same thing. It won’t move the price and is unlikely to nudge the needle much on the spread either. Amundi Prime Global’s spread was around 100th of a percent on 8 November. A non-issue.

In theory, you have until 21 November to sell (that’s the ETF’s last day of LSE trading). But InvestEngine for one told its ISA owners to sell by 31 October or else it’d take action unilaterally around 7 November.

‘Unilateral’ here means your broker sells for you if haven’t opened a (taxable) GIA with them.

If you do have such a taxable account and you don’t sell beforehand, then your broker will instead transfer the new-style Prime Global ETF into your GIA upon completion of the merger. The merger is slated for 22 November but that’s subject to change.

However, it’s a bad idea to let an ETF without UK reporting fund status hang around outside your tax shelters. (See the ‘Taxable account’ section below).

I don’t think you can depend on the extra 30 days the stocks and shares ISA rules imply you get either.

That’s because the communications received by affected investors suggest that brokers will either sell or transfer on their own timeline if you don’t act yourself.

Does delisting affect SIPPs?

Amundi’s notice to shareholders says:

The Receiving Sub-Fund is eligible for self-invested personal pension (SIPP) purposes under UK tax law. Nevertheless, each SIPP provider may impose its own restrictions.

(The ‘receiving sub-fund’ referred to is the Xetra-listed version of Prime Global.)

I haven’t found any reports of SIPP owners being affected. Still, you may need to take action if your broker doesn’t allow you to trade European-listed ETFs.

One broker advises (with reference to shares generally) that you’ll have to call its telephone trading desk to offload delisted stock if you miss the deadlines. A bit tedious and likely more expensive.

Still, if you fancy holding the new ETF and your current platform doesn’t do Europe then you could transfer it to a different broker who does. There are enough decent options, though it does mean incurring charges on another platform.

My own brokers don’t support European-listed ETFs. So personally I’d sell and replace Amundi Prime Global before the last day of trading.

Taxable accounts and capital gains events

Without UK reporting fund status, capital gains are taxed at your marginal income tax rate. Even worse, the CGT exemption allowance does not apply.

Bad, bad, bad.

However, being an unrecognised overseas fund needn’t stop Amundi Prime Global from achieving UK reporting fund status.

Other LSE delisted Amundi ETFs found this happy place in good time.

For example:

  • EPRE was delisted on 5 July 2023. The LSE sub-fund merged with versions trading on multiple European exchanges. HMRC states reporting fund status came into effect for those back on 31 January 2018.
  • WGES was delisted on 1 February 2024. It merged with its Xetra counterpart which had gained reporting fund status from 17 January 2024.
  • RUSG was delisted on 8 July 2024. It merged with its Xetra equivalent, MWOT. Reporting fund status was granted from 8 July 2024.

So anyone who doesn’t want to trigger a capital gains event by selling PWRU / PR1W may not have to worry about UK reporting fund status if they can wait for the Irish incarnation to appear.

In fact, I haven’t yet found an example of an Amundi ETF delisting from the LSE and only leaving behind a non-reporting fund version.

That said, I can’t claim to have searched every instance. And this time might be different.

Obviously this is a tricky decision that could backfire either way. Ideally, Amundi can give you a straight answer about its plans if you need it. You can call customer service on 0207 074 9598 or email Retail-UK-ETF@amundi.com

You can also check which overseas funds have UK reporting fund status by downloading an Excel document from the dedicated gov.uk page. Search the spreadsheet using the fund’s ISIN code.

The Irish version of Amundi Prime Global is not present in the latest update dated 9 October 2024.

Why do Amundi ETFs keep delisting?

Amundi isn’t the only ETF provider to have delisted ETFs from the LSE over the past several years. But it has been hyperactively pruning its range in the wake of its 2022 takeover of the Lyxor ETF brand.

Normally, delistings eliminate niche products that are struggling to make a profit.

However Prime Global has $1.5 billion under management, according to Amundi.

So Amundi is not delisting the ETF because it failed to gain traction in the market. In fact, it’s protecting the fund’s competitiveness by moving it to Ireland.

Amundi has obviously decided that move can’t wait for the outcome of its OFR application. So it’s seemingly not too bothered about losing any UK investors caught in the regulatory cross-fire.

Indeed the company has done little more than provide the 30-calendar-day notice period required. Meanwhile affected owners are struggling with ineffectual communication from their brokers.

All of which makes me think customer service still has a long way to go in the investment industry.

Are other large ETFs at risk?

I’d be surprised if this proves to be a problem that gets notably worse in the future.

The UK is the second biggest European market for UCITS funds (ETFs fall into that category).

Moreover ETF Stream recently quoted BNP Paribas Asset Management’s global head of business development ETF and index solutions, Lorraine Sereyjol-Garros, as saying:

Some clients, such as in the Nordics, Middle East, Latin America, and Asia prefer LSE listings over mainland Europe, so it enables us to target the domestic market and international clients

Thankfully then, we’ve still got market power as a country. It seems likely to me that fund managers who haven’t launched new products in the UK over the past few years were waiting for OFR to go live.

Unsurprisingly implementation kept being delayed, though it seems we’re finally off to the races now.

Be that as it may, delistings are a natural part of the ETF ecosystem. And yet retail investors aren’t always being given enough time – nor adequate information – to confidently respond.

Brokers are on point for this as they hold the direct relationship with the customer.

It wouldn’t be that hard to write a comprehensive guide to delisting. They’re welcome to start with the points raised above.

Take it steady,

The Accumulator

  1. Scroll to the Changes to investments held in a stocks and shares ISA section. []
{ 30 comments… add one }
  • 1 Nutkin November 12, 2024, 1:08 pm

    Thanks for the comprehensive explanation. Well, that was a risk that I hadn’t previously considered! As someone who is currently going through a process of ISA portfolio simplification I’m now left wondering if I should mitigate this risk by spreading funds across multiple global ETFs. It hardly seems worth the faff, but even so …

  • 2 Wannabe Retiree November 12, 2024, 2:30 pm

    Thanks as always for the very useful article.
    I’m holding AMUNDI INDEX SOLUTIONS PRIME GLOBAL UCITS ETF DR (PRIW) with Fidelity. Got the follwoing message from them:
    Amundi ETF has announced a proposed merger of funds of Amundi Index Solutions Prime Global UCITS ETF DR into Amundi Prime Global UCITS ETF Dist.
    Fidelity have reviewed the event and will not be able to support holding Amundi Prime Global UCITS ETF Dist on the platform. On this basis, Fidelity will sell down any holding you have in Amundi Index Solutions Prime Global UCITS ETF DR plc as at close of business on the 14 November 2024.

    Talking about being a forced seller. LOL But some of the consequences you highlight are being mitigated by this approach.

  • 3 GM November 12, 2024, 3:11 pm

    I smiled when this story appeared as I have been wrestling with this ever since I stumbled upon the announcement. Both II and HL were slow to flag it and have not been entirely reliable in the answers they offered.
    I liked PRIW — it’s CHEAP, performs well and has very little China exposure. I would have preferred an accumulating option in GBP, but they don’t offer one. It has been the largest tracker in my SIPP and has scale enough to avoid horrible spreads. I shall miss it. I’d add the timing of the delisting is smack bang in the middle of window that Amundi normally declares/and or pays dividends, adding to the fun. SWLD here I come. If someone else were to offer a cheap, GBP, accumulating Solactive Developed Large/Mid tracker I think it might tick a lot of Monevator reader’s boxes…

  • 4 David 14 November 12, 2024, 3:56 pm

    I swore never to invest in another Amundi fund after my experience with them. earlier this year. I had invested in Amundi Index MSCI World SRI. They sent a notice around saying they were changing the listing for this and that my GBP interest would be transferred to an alternate GBP listing of the same fund. I was fine with that so did nothing. What they actually did was transfer me to a EUR listing of the same fund and because it was post Brexit that holding could not be added to (and indeed to sell I had to do it over the phone with the broker). They were completely unapologetic and ignored the fact that their communications had been misleading. Eventually gave up trying to sort things out, sold over the phone and promised that I’d never invest in an Amundi product ever again.

  • 5 oldie November 12, 2024, 4:13 pm

    Hi
    I am pleased that the simplicity of investing in ETF and ISA is preserved!

  • 6 The Accumulator November 12, 2024, 5:01 pm

    @Wannabe – That is at least clear cut from Fidelity. Probably one of the better communications I’ve seen. Are you holding in an ISA? Can you remember what date you received the message?

    @GM – I suspect Amundi will be back before long once this OFR business is working properly. They released an All-Country ETF on other stock exchanges that looks right up your alley but it was clearly too much faff to list it here. Same question to you: what dates did you receive the comms from ii and HL? I’m just wondering how slow the slowest broker can be?

    @David – that’s v.poor from Amundi.

    @Oldie – Haha. Those were my thoughts exactly when I was writing this piece!

  • 7 Wannabe Retiree November 12, 2024, 5:17 pm

    @TA the initial message came on 24 Oct and the update confirming their approach on 7 Nov. I hold them in SIPP and ISA.

    @GM I was looking at LGGG which references Solactive. But total costs are higher than SWLD.

  • 8 GM November 12, 2024, 5:27 pm

    Hello! @The Accumulator

    ii sent me a vague note on 30/10/24 — this was after I had asked them about it. They also suggested it would be fine in an ISA.

    HL contacted me on 1/11/24 — again after I had asked.

    Cheers!
    ——————–
    @GM – I suspect Amundi will be back before long once this OFR business is working properly. They released an All-Country ETF on other stock exchanges that looks right up your alley but it was clearly too much faff to list it here. Same question to you: what dates did you receive the comms from ii and HL? I’m just wondering how slow the slowest broker can be?

  • 9 Martin T November 12, 2024, 5:28 pm

    Presumably if all Monevator readers were to ring Amundi customer service about this issue….

  • 10 Andrew November 12, 2024, 7:06 pm

    The last time I was notified of a withdrawn fund (in a workplace pension actually), I immediately hit the sell button for execution the next working day.

    It’s not worth the risk of having funds in limbo

  • 11 Peter Rabbit November 12, 2024, 9:21 pm

    Thanks for having a thorough look into this @TA. Those previous examples of Amundi delistings are a good find and seem to bode well for holdings in taxable accounts.

    @Nutkin re spreading over multiple ETFs – I decided to limit exposure to any individual ETF to what I could just about afford to lose if the provider screwed up, and I’m happy with that decision after dealing with this episode! I don’t just hold global ETFs though, which makes it easier to not go over my limit on any one.

  • 12 Peter Rabbit November 12, 2024, 9:42 pm

    Another potential risk I looked into was inheritance tax should a holder pass away with the new ETF not having acquired reporting status – what I could find on HMRC made it seem unclear whether inheritors would only need to pay CGT on gains since death for non-reporting funds, as they would for reporting funds. If anyone knows better, it would be useful to understand.

  • 13 Hariseldon November 12, 2024, 11:37 pm

    I had a significant holding with HL in an ISA and got the message on 1/11/24, sold the holding about 5 minutes later and reinvested in the Invesco All World ETF.

    Its not the first ETF to close on me unfortunately but I was surprised that a Global Tracker would do so, thank you for the detailed explanation.

  • 14 Martin T November 13, 2024, 6:41 am

    The SPDR MSCI AWCI UCITS ETF (confusingly ACWI ticker) now appears to be the cheapest GBP denominated LSE Global ETF at 0.12%, albeit All World not Dev only. Charges were reduced recently, and it still shows at a higher rate on some platforms.

  • 15 GM November 13, 2024, 9:13 am

    @Wannabe Retiree — Yes, LGGG looked interesting, but the spreads scared me, is that what you’re referring to re costs? Hence SWLD.

    @Martin T — the ACWI is, as you say, not just developed. That is why I favour SWLD, which is just developed, it tracks PRIW very closely, or should I say PWRU, as it accumulates. Also 0.12%.

    Someone, please tell me my instinct to hang on for the PRIW dividend date on my SIPP holding is silly.

  • 16 GM November 13, 2024, 9:51 am

    @Wannabe Retiree — Yes the LGGG looked a good swap, but the fees! I assume you mean the spread?

    @Martin T re ACWI — If you don’t want the developing world, then SWLD does a better job, also 0.12% Tracks and beats PRIW PWRU over time, not a crazy spread.

  • 17 GM November 13, 2024, 9:52 am

    @Wannabe Retiree — Yes the LGGG looked a good swap, but the fees! I assume you mean the spread?

    @Martin T re ACWI — If you don’t want the developing world, then SWLD does a better job, also 0.12% Tracks and beats PRIW PWRU over time, not a crazy spread.

    Someone tell me my nagging instinct to hang on to the SIPP holding for the dividend is silly…

  • 18 The Accumulator November 13, 2024, 11:57 am

    @all – thank you for letting me know broker communication dates. All pretty poor given the announcement was Oct 16 and the clock was ticking. InvestEngine was Oct 19 if online reports are accurate.

    @GM – if you sell before the ex-dividend date then the dividend accrued to date will be in the price. If you sell during ex-dividend period then you’ll still get the divi. Terrible comms from II suggesting your ISA holding was fine.

  • 19 Jam November 13, 2024, 1:29 pm

    Interesting article, thanks.

    Also interesting is that some people, e.g. GM, just want to track the developed markets and not the whole world including developing.

    I have always been happy tracking the FTSE all world through e.g. VWRL/FWRG with the belief that the future risk-adjusted returns would be better on them, even if the rewards considered in isolation are slightly lower.

    Does this assumption of improved risk adjusted rewards still look likely to hold going forward, given the that the word ‘tariffs’ is being used in Washington DC?
    Anyone got a good crystal ball?

  • 20 Peter Rabbit November 13, 2024, 1:32 pm

    @TA re notification times, iWeb only sent one on Nov 4. x-o sent me a letter (!) dated Oct 18, presumably arriving a few days later (but was not informative about what the status of any holding on their platform would be after the merger – for a GIA, which is where I held it with them).

  • 21 Martin T November 14, 2024, 3:51 am

    @GM thanks I’d missed that one, although in this case wanted Dev World, hence ACWI. This situation is another reason for spreading large holdings across several similar ETFs, preferably with different companies.

  • 22 The Accumulator November 14, 2024, 7:39 am

    @PeterR – thanks! From one angle, you could make the argument that iWeb and X-O are obviously cheap and cheerful, so you’d expect them to be slow. But @GM notes that HL didn’t issue guidance until 1 Nov (and even then after prompting) and they’re supposedly the leading light in customer service.

    @Jam – re: out-of-favour emerging markets – on the one hand you have a frothy US market, on the other, deglobalisation. When in doubt, diversify!

  • 23 Student Grant November 14, 2024, 8:01 am

    Bit confused – this advice seems to say that “Investments in non-reporting and reporting offshore funds can be held within the ISA wrapper.” So why can’t the new (as yet) non-reporting PRIW be held in an ISA?

    https://www.gov.uk/government/publications/offshore-funds-self-assessment-helpsheet-hs265/hs265-offshore-funds

  • 24 The Accumulator November 14, 2024, 10:23 am

    Because it isn’t recognised yet by the FCA. See the list of ISA qualifying investments here: https://www.gov.uk/guidance/stocks-and-shares-investments-for-isa-managers

    Prime Global’s reporting status is a separate issue that only matters outside of an ISA.

    The new Irish domiciled, Xetra-listed ETF tickers are MWOZ and F50B. I’ve just noticed that MWOZ will trade in GBP. What’s the betting MWOZ will be aimed squarely at UK investors once the fund is recognised and can be LSE-listed?

  • 25 Peter Rabbit November 17, 2024, 10:43 pm

    Just to add, Amundi have told me that they do plan to get UK tax reporting status for the new funds.

  • 26 Ramzez November 21, 2024, 10:24 am

    I had a Baillie Gifford closes Health Innovation fund which apparently is closed. It was in ISA and has been in minus 40% territory for a while. Nobody notified me neither Baillie not my broker (II in that case). The way I found out as it was on regular investment schedule and the trade was rejected.

  • 27 GM November 21, 2024, 10:38 am

    @Ramzez
    In a way it’s nice not to be reminded that you are invested in a Baillie Gifford fund. II cheerfully tipped Positive Change at its peak and I rode it all the way down… On a more serious note, I don’t know why II and the others don’t automatically pass on corporate actions as they are announced.

  • 28 Ramzez November 21, 2024, 12:07 pm

    @GM yup. They only seem to pass voting actions. Maybe there is some communication tick box I forgot to click who knows. I did email them to ask though.

  • 29 Yevheniia November 28, 2024, 6:02 pm

    I missed the delisting date, InteractiveBrokers tell me they notified me, but I don’t have notifications neither in Notifications Center nor on my mailbox. I am trying to get understanding from the broker how do I sell these stocks now? Today, IBKR shows me -20% market value of my investment in PRWU… Although, if stock is delisted, and global market didn’t drop, why my investment decreased by 20%? So, my question is how do I sell stocks now? Maybe anyone figured it with their broker, especially if you also use IBKR?

  • 30 The Accumulator November 29, 2024, 12:23 pm

    @Yevheniia – There’s no sign your ETF dropped 20% from what I can see based on publicly available information. My guess is IBKR’s system is screwy.

    PRWU has this ISIN number: LU2089238203
    It’s been merged into the Xetra-listed: F50B, ISIN: IE0009DRDY20

    Google for prices on the internet. It looks fine:
    https://www.cnbc.com/quotes/F50B-DE
    https://www.tradingview.com/symbols/XETR-F50B/

    Here it is on Amundi’s site:
    https://www.amundietf.co.uk/en/professional/products/equity/amundi-prime-global-ucits-etf-acc/ie0009drdy20

    Here’s PRWU:
    https://www.amundietf.co.uk/en/professional/products/equity/amundi-prime-global-ucits-etf-dr-c/lu2089238203

    PRWU’s performance chart cuts off from Nov 19 so looks like they went ahead with the merger as planned on Nov 22, but hard to know for sure. The timeline was subject to change.

    Both versions of the ETF trade in USD and there shouldn’t be any loss associated with the merger.

    Either way, your investment is now F50B and IBKR trades Xetra ETFs. So you should be able trade once they’ve got their act together.

    Did you hold it in an ISA? If so, then the article explains that complication.

    Hope they sort it out soon for you.

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