BBA has submitted its response to FSA's consultation on restricting UCIS sales. It shares FSA's views that firms should sell these products only to investors for whom they are suitable, but thinks the proposals may have unintended consequences. It says the certification requirements FSA proposes would have the effect of making it difficult to market UCIS even to experienced high net worth investors. It also notes the definition of "non-mainstream pooled investment" is not specific enough and risks being subject to regulatory arbitrage. (Source: BBA response to CP12/19)