AMF identifies issues in REIT advisory practices

The Autorité des marchés financiers (AMF), France’s financial markets authority, released a report in October 2026 highlighting major flaws in how investment advisory firms marketed and advised clients on Real Estate Investment Trusts (REITs). The report focused on four institutions, two of which specialized in REITs managed by their own affiliated companies, while the two largest handled over 38,000 subscriptions from 2022 to mid-2025.

Review covers six key areas

The AMF examined six areas: the structure of REIT offerings, distribution strategies, pre-contractual and commercial documentation, client information during the product’s life, suitability evaluations, and compliance roles. The analysis looked at the ten most recent REIT subscriptions from each institution, totaling 40 cases. The AMF noted that a risk map published in July 2023 should have alerted distributors to the risks of REITs, such as devaluations and poor management company disclosures.

Institutions failed to disclose REIT risks

All four institutions failed to provide clients with full pre-contractual information about REITs, including exit conditions, consequences, and recovery timelines for entry fees. Post-subscription documents from the REIT producers also lacked essential details about illiquid instruments. The AMF noted that simply stating a product was “illiquid” was not enough when risks had already materialized.

Commercial documentation not properly tracked

Three of the four institutions could not show that clients received the necessary commercial documentation during the advice process or identify the version used. At one institution, the documents available were dated three to four years earlier and predated the first drop in share prices. The AMF rejected the idea that materials created by the management company would absolve distributors of responsibility.

Standardized reports ignored key risks

All institutions used standardized suitability reports that did not address the poor market conditions, declining share values, or liquidity issues affecting REITs. These reports failed to explain why an illiquid and devalued REIT was still considered suitable for a client’s financial situation. The AMF said the reports were uniform and did not meet legal requirements for personalized suitability assessments.

Client questionnaires overlooked REIT risks

Three of the four institutions did not include questions about REIT liquidity in their client knowledge questionnaires. At one institution, clients with no REIT experience were recommended without specific warnings. Another institution exceeded internal limits on REIT investments without adjusting the advice. The AMF criticized attempts to shift suitability evaluation responsibility to clients, stating such clauses do not absolve providers of their duty.

Credit financing risks ignored in suitability reports

The AMF emphasized the need to address credit financing in suitability reports. In two institutions, reports for clients who had taken out loans to invest contained no personalized risk assessments. This affected 40% of the cases at one institution and 20% at another. The AMF pointed out that credit financing was treated as a minor factor, despite being crucial to the suitability analysis.

AMF provides guidance for future compliance

While the AMF did not name specific institutions or prove fault in any distributor, it provided a benchmark for responsible professionals and outlined legal requirements that should have been met. The summary offers a framework for reviewing each case, focusing on the documents provided before advice, the version of materials used, and the personalization of suitability reports. The AMF also stressed that the deadline to act against an advisor who failed to inform clients about REIT risks cannot begin until the losses actually occur.