Does land banking come under Collective Investment Scheme?

I met with four people who were sold to invest in a land banking scheme. The promoter gave them a guarantee (in the form of an option) to buy back their investment at the end of 12 months for a full refund of their principal plus a guaranteed return.

These investors have now submitted their redemption request, but the promoter refused to honor the agreement and gave some unsatisfactory and unclear explanations.

One investor made a complaint with MAS and were told by the MAS official that land banking did not come under MAS. In my view, unless I am mistaken, land banking should fall under the scope of a collective investment scheme, which is administered by MAS. There are controls under the law on collective investment scheme to prevent the misappropriate of the funds collected from investors. This risk applies to land banking as well.

I will appreciate if a practising lawyer can clarify if land banking comes under the collective investment scheme?

Tan Kin Lian