In Ian Gray & Associates Ltd v. Investments Ltd (in liquidation), the defendant applied to strike out parts of an amended particulars of claim in which the claimant pensions adviser asserted that a self invested personal pension scheme (SIPP) amounted to a collective investment scheme (CIS). The issue was whether the bespoke arrangements fell within one of two exemptions to the general definition of a CIS under the Financial Services and Markets Act 2000 (FSMA) (Collective Investment Schemes) Order 2001: either the personal pension scheme exemption or the common accounts exemption. The court granted the defendant’s application as the investment arrangements formed part of a bespoke SIPP for the purposes of the pensions exemption, and therefore they did not amount to, or form part of, a CIS. (Source: SIPP ruled not a CIS under FSMA)