No—provided design guardrails are followed. A scheme becomes an MIS when clients contribute money to obtain benefits produced by a pooled or common enterprise where they lack day‑to‑day control. In Cash Hub, client balances remain segregated and attributed to each client account level; funds are moved operationally to support settlement and liquidity, not pooled for common investment performance. FinClear retains underlying interest and instead pays clients under the CRP (its own contractual obligation). Because clients do not hold a pro‑rata interest in a pooled return and FinClear is not exercising discretionary investment management to generate a collective yield, the arrangement should not be characterised as an MIS.