Comparing Commercial Property Across Borders: A Six-Lens Framework for Developed and Emerging Markets

By Fredrick Ndwiga | 2026-10-14 | 28 min read

Why the same 8% yield can describe very different investments in Nairobi, Singapore, Dubai, Bangkok, Bali, Johannesburg, London and the United States, and how to compare them on consistent terms.

Abstract

Cross-border commercial real estate investment has grown substantially, yet the analytical frameworks used to compare opportunities across jurisdictions remain underdeveloped. This research paper addresses a fundamental problem in international real estate allocation: the headline yield—the most commonly cited metric—conceals critical differences in legal tenure, income durability, financing conditions, currency exposure, transaction costs, and operating risk. Drawing on published market data, legal summaries, and practitioner sources across eight markets (Kenya, Singapore, the United States, the United Kingdom, the United Arab Emirates, Thailand, Bali/Indonesia, and South Africa), we develop a six-lens framework that imposes analytical discipline on cross-border comparison. The framework is applied sequentially: access and tenure first, followed by income quality, capital and financing, currency and repatriation, transaction friction and liquidity, and operating and execution risk. We demonstrate through illustrative calculations that a flat 8% income yield delivers internal rates of return ranging from 6.9% to 8.0% depending solely on the tenure of the legal right held. We further show that Nairobi's prime office yield of 8.5% sits approximately at the 91-day Treasury bill rate of 8.778% as of October 2026, meaning the asset carries no visible premium over short-dated government paper before property-specific risks are priced. The framework does not rank markets; rather, it ensures that comparison is conducted on consistent terms, with limitations explicitly acknowledged. We conclude that defensible cross-border analysis begins with the investor's mandate—objectives, time horizon, base currency, risk tolerance, and permissible structures—and proceeds to test access before underwriting return.

Keywords: cross-border real estate, commercial property, investment framework, tenure, yield analysis, capital markets

1. Introduction

1.1 The Problem of Incommensurable Metrics

International commercial real estate investment has expanded rapidly. Global institutions were set to deploy $144 billion into commercial real estate in 2026, according to Knight Frank's Active Capital Survey, which captured the investment intentions of 119 of the world's largest global real estate investors representing over $1.4 trillion of assets under management[reference:0]. Eighty-seven percent of survey respondents by AUM intended to increase direct CRE investment in 2026, with 62% expecting to be net buyers of real estate assets, signalling strong acquisition appetite[reference:1].

This capital is moving across borders with increasing frequency. Yet the analytical infrastructure for comparing markets remains fragmented. A Hong Kong family office evaluating a Singapore office building uses different criteria, different data sources, and different risk assumptions than when evaluating a Nairobi industrial park or a Bangkok retail centre. The consequence is that comparison becomes anecdotal rather than analytical—investors default to familiar markets or rely on broker narratives rather than structured assessment.

The source of this problem is definitional. A yield is a ratio of income to price. But the numerator may be an asking rent in one market and an achieved rent in another. It may be gross of landlord costs in one report and net in the next. The denominator may exclude purchase taxes that add several percentage points to the cost of acquisition. And the investor's own return is measured in a currency that may not be the currency of the rent. These definitional differences are compounded by structural differences in legal systems, financing markets, and regulatory regimes that determine whether an investment is legally possible, what structure is required, and what costs are embedded.

1.2 Research Question

This paper asks: How can a sophisticated investor compare commercial property investments across developed and emerging markets on consistent analytical terms?

We address this question by developing a six-lens framework and applying it to eight markets that represent a range of legal traditions, currency regimes, capital market depths, and ownership structures. The framework is not a ranking methodology. It is a decision-support tool designed to ensure that comparison is disciplined, evidence-based, and aligned with the investor's specific mandate.

1.3 Contribution and Structure

This paper makes three contributions. First, it synthesises legal, financial, and operational considerations into a single sequential framework that can be applied across diverse markets. Second, it provides sourced cross-market evidence on tenure, foreign access, tax treatment, and financing conditions. Third, it demonstrates through illustrative calculations how structural differences—particularly in tenure—materially affect returns.

The paper proceeds as follows. Section 2 reviews the relevant literature on cross-border real estate investment. Section 3 describes the methodology and data sources. Section 4 presents the six-lens framework in detail. Section 5 presents findings. Section 6 discusses implications for different investor types. Section 7 addresses limitations. Section 8 concludes.

2. Literature Review

2.1 Cross-Border Real Estate Investment Motives

The academic literature identifies several motives for cross-border real estate investment: portfolio diversification, yield enhancement, currency hedging, and access to markets with superior growth prospects. However, the literature also emphasises that cross-border investment introduces unique risks—political, currency, legal, and informational—that are not present in domestic investment.

Wang's (2024) doctoral thesis at the University of Manchester provides the most comprehensive recent analysis of cross-border real estate investment determinants. Using a panel data framework encompassing 52 countries from 2003 to 2021, the research demonstrates that robust economic growth and a strong domestic financial system attract foreign real estate investments. A key finding is that a 1% increase in global economic and political uncertainty reduces foreign real estate investment greenfield inflows in developing countries by 0.3% to 0.6%[reference:2][reference:3]. The research further establishes that a strong governance regime attracts higher foreign capital flows into real estate sectors, though different dimensions of governance have varying levels of influence. The effects of institutional quality on foreign real estate investment vary for developed and emerging economies and are also different for different modes of investment[reference:4].

At the city level, Wang's analysis of bilateral real estate investment flows between 715 pairs of global cities found that a 1% increase in geographic distance is associated with a decrease in flows ranging from 0.20% to 0.28%, while the economic size of cities boosts the scale of flows between cities ranging from 0.04% to 0.20%. Most institutional distances are negatively relevant to foreign real estate investment flows[reference:5]. This finding has direct implications for the framework: the institutional distance between an investor's home market and a target market is a measurable risk factor that should be assessed alongside financial metrics.

2.2 Transparency and the Cost of International Investment

A substantial body of academic research addresses the role of market transparency in international real estate investment performance. The Journal of Real Estate Finance and Economics published research investigating the importance of market institutions for the performance of international property investors during the 1996–2007 period. The results show that international property companies underperform local property companies in the early years of the sample period. This underperformance is driven by the political environment, the level of economic integration, and the transparency of the real estate market in target countries[reference:6]. Critically, the underperformance of internationals disappears in the later years of the sample period, and so does the significance of the aforementioned factors in explaining performance differences. These findings suggest that the increased transparency of the global real estate industry has leveled the playing field for foreign property investors[reference:7].

This finding is particularly relevant to the six-lens framework. It suggests that transparency improvements—driven by the internationalization of real estate service providers, the rise of common investment vehicles, and more sophisticated performance benchmarks—have materially reduced the informational disadvantage faced by cross-border investors. However, the research also notes that the quintessential characteristic of real estate—its immobility—makes it especially vulnerable to weak institutional settings, which explains why real estate investment remained primarily local until relatively recently[reference:8].

2.3 Global Capital Flows and Market Liquidity

JLL's Global Capital Liquidity Dynamics research provides proprietary market indices that reveal growing investor conviction and unprecedented lender competition. JLL's Bid and Credit Intensity Indices indicate this opportunity window will persist through year-end. Global credit competition soared to an all-time high in April 2026, fuelled by a massive wave of refinancing and large loan placements. With a near-record number of distinct lenders active across all capital sources, lenders are competing to place capital and are expanding their risk tolerance[reference:9].

Global direct investment carried strong momentum into the second quarter with volumes rising by 28% year-over-year. Activity in the Americas increased by 26%, with the U.S. performing strongly and Canada emerging as the second most liquid market globally. In EMEA transaction volumes were 27% higher, with Germany and France posting strong growth. Asia Pacific posted its most active second quarter in five years, with investment up by 38% as Japan and Australia led liquidity and Singapore recorded exceptional growth[reference:10].

This liquidity cycle is relevant to the framework's fifth lens—transaction friction and liquidity—because it determines how easily capital enters and exits a market, at what cost, and with what degree of pricing certainty. The divergence between credit and investment sales markets since early 2025 is also significant: competitiveness and market activity in the credit markets are rising more sharply than bidder competitiveness, partially accounted for by an above-average share of refinancing activity relative to new acquisitions[reference:11].

2.4 Asset Selection versus Market Selection

McKinsey's 2026 real estate research identifies a fundamental shift in the drivers of real estate performance. Asset selection accounted for approximately 70% of performance differentials in 2025 (relative to country-specific benchmarks), materially outweighing the effect of country- or property-type allocation decisions. This marks a meaningful increase from 2020 to 2022, when asset selection accounted for less than 50% of return dispersion[reference:12].

This finding has profound implications for cross-border investment strategy. It suggests that choosing the right submarkets, tenant profiles, and capital structures may matter as much, if not more, than broad asset-class exposure. In 2025, capital increasingly flowed not toward entire property categories but toward more specific subcategories. As dispersion in outcomes within asset classes has widened, players are more frequently adopting niche positioning to differentiate beyond broad market exposure[reference:13].

Data centres illustrate this shift. Power-constrained, top-tier hubs are becoming increasingly consolidated, pushing incremental development and leasing into power-rich, next-tier markets. In the United States, nearly eight gigawatts of leasing in 2025 occurred in next-tier locations as hyperscale and AI demand chased available power rather than traditional core markets. A similar dynamic is emerging in Europe, where demand is shifting from constrained tier-one hubs to next-tier markets such as Iceland and Sines, Portugal, where power availability and cost are more favorable[reference:14].

2.5 Office Market Dynamics

CBRE's 2026 Global Investor Intentions Survey, drawing on a global survey of over 1,400 investors across North America, Europe, Asia-Pacific and Latin America, found that investors across all regions indicated they plan to buy and sell more assets than last year, with the magnitude of this expected activity the highest in North America. Value-add and core strategies were the most preferred globally[reference:15].

Knight Frank's Active Capital Survey 2026 found that offices have re-emerged as the most targeted asset class (69% of investors), while over half (56%) of respondents are planning to invest in retail assets, indicating opportunities as the sector emerges from its right-sizing phase. Investors are, however, increasingly differentiating between well-located, ESG-compliant assets that can meet modern occupier demands and those facing long-term obsolescence[reference:16].

JLL's Global Real Estate Perspective for August 2026 reports that global office leasing rose further to a new post-pandemic high, with the U.S. leading activity. Global office leasing activity rose by 2% year-over-year in Q2, with growth in the U.S. and Europe offsetting declines in Canada and Asia Pacific. Volumes over the first half of the year increased by 1% on H1 2025 to a new post-pandemic high. The global vacancy rate declined further during the quarter to 16.5%. New deliveries remain near record lows in the U.S., with completions set to fall by 60% this year. In Europe, new supply is expected to be at the lowest level since 2011[reference:17].

3. Methodology and Data Sources

3.1 Research Design

This paper employs a structured analytical approach. We do not conduct primary empirical research; rather, we synthesise published data and legal summaries into a comparative framework. This approach is appropriate because the research question concerns how to compare, not what to compare. The framework is designed to be applied by investors and advisers to specific opportunities, with market-specific data inputs.

3.2 Market Selection

The eight markets analysed—Kenya, Singapore, the United States, the United Kingdom, the United Arab Emirates, Thailand, Bali (Indonesia), and South Africa—were selected to represent:

• Legal diversity: common law, civil law, and mixed systems
• Currency regimes: hard currencies, managed floats, and pegged currencies
• Capital market depth: deep institutional markets and emerging markets
• Foreign ownership regimes: unrestricted, restricted, and structured access
• Asset class coverage: office, industrial, retail, hospitality, and mixed-use

3.3 Data Sources and Limitations

Data was drawn from the following source categories, in order of priority:

Key limitation: The eight markets do not publish rents, yields, and vacancy on identical definitions. This paper does not rank them, and where comparable data is unavailable, we state that limitation explicitly. Several legal entries rest on law-firm and practitioner summaries rather than the statute itself; these are labelled accordingly.

4. The Six-Lens Framework

4.1 Framework Overview

The framework asks six questions in a fixed order. The order matters: an asset that fails the first lens does not need to be analysed through the remaining five.

4.2 Lens 1: Access and Tenure

Tenure is the foundational lens because it determines whether the investment is legally possible and, if so, what the investor actually owns. A freehold interest, a 99-year leasehold, a 30-year registered lease, and a company share transfer are fundamentally different assets, even if they relate to the same physical building.

The following table summarises verified foreign access rules and structural features across the eight markets. It is a starting point for legal counsel, not a substitute for it.

4.3 The Tenure Arithmetic: Why Duration Matters

A finite property right behaves like a wasting asset. The following illustrative calculation assumes flat income at 8% of the purchase price, no rental growth, no residual value when the right expires, and no tax or acquisition costs. It isolates the effect of tenure duration on return.

The gap between 8.0% and 6.9% is the cost of a shorter right. In practice, renewal options, rental growth, and exit value would offset part of it. Each should be priced explicitly rather than assumed. The critical point is that tenure duration is not a legal formality; it is a return determinant that must be modelled.

4.4 Lens 2: Income Quality

Income quality is where asset-level analysis begins. Market averages cannot substitute for a tenancy schedule. The questions are consistent across markets: how many tenants, how concentrated, how long the unexpired terms run, what escalation clauses apply, who stands behind each lease, and whether rent is actually being collected.

Lease structures vary materially across jurisdictions. South African commercial leases commonly use fixed compounding annual escalations and operate largely on freedom of contract, with no statutory renewal right. Thai leases may be registered for up to 30 years, but only the first term is enforceable. Kenyan commercial leases may be denominated in US dollars while the underlying economy operates in shillings. A lease that appears similar on a summary sheet can carry very different protection depending on the governing law.

Analytical requirement: The tenancy schedule must be verified lease-by-lease. Market-level occupancy data is a starting point, not a conclusion.

4.5 Lens 3: Capital and Financing

A property yield is a price of risk. To interpret it, the investor needs a reference point. The simplest is the spread between the yield and the local short-term government rate.

In Kenya, a Business Daily report on Knight Frank's first-half 2026 review put the prime office yield at 8.5%, unchanged for three years. The Central Bank of Kenya reported the 91-day Treasury bill at 8.778% on 5 October 2026. The same report put longer-dated government bonds at 11% to 13%. These figures come from different dates and sources, and the report does not state whether the 8.5% is gross or net. The comparison is therefore indicative. It still demonstrates why a bare yield cannot be read across markets without the local rate beside it.

Debt makes the issue sharper. Where borrowing costs exceed the income yield, leverage reduces the return on equity instead of increasing it. In Kenya, the average commercial bank lending rate was 14.34% in August 2026 (CBK). Borrowing at 14.34% to buy an asset yielding 8.5% implies negative leverage unless rental or capital growth is strong. The lending rate is a system-wide average rather than a commercial mortgage quote, so the test should be rerun with actual indicative terms. The principle remains: run the leverage test for every market with the investor's actual financing terms, not an average lending rate.

The global financing environment provides important context. JLL's research indicates that a hyper-competitive financing environment is underway, with the sheer volume of debt capital chasing yield at near all-time highs. Lenders are moving aggressively to win business, driving a rise in average winning bank loan-to-value rates since the start of the year. When combined with a steady rebuilding of investor bidding pools, this signals a powerful new liquidity cycle[reference:18].

4.6 Lens 4: Currency and Repatriation

An investor in one currency earning rent in another carries exchange-rate exposure twice: on the income stream and on the exit proceeds. Some markets add procedural constraints.

In South Africa, funds introduced for a property purchase must be declared to the Reserve Bank and routed through an authorised dealer. In Thailand, a foreigner buying a foreign-quota condominium unit must bring in funds from abroad. A stable exchange rate over one year, as the Kenyan shilling has shown (about 129.24 to the dollar in October 2025 and 129.89 in October 2026, a move of about 0.5%), says little about a ten-year hold.

Analytical requirement: All cross-border return analysis must be presented on a currency-adjusted basis. Where hedging is unavailable or prohibitively expensive, the currency exposure must be explicitly quantified and stress-tested.

4.7 Lens 5: Transaction Friction and Liquidity

Entry and exit costs are part of the return and fall on different parties at different times. A buyer in Kenya pays stamp duty of up to 4%. A foreign seller of United States real property interests faces withholding of 15% of the gross sale price, which can exceed the actual tax due and is later reconciled. In Singapore, commercial buyers are not subject to the additional buyer's stamp duty applied to residential property, but institutional deals are often structured as share transfers precisely because of stamp duty and control provisions.

Liquidity is harder to measure. Transaction-volume data is not published on a common basis across the eight markets, which is one reason we do not rank them. Where liquidity data is unavailable, the investor should assess the likely buyer universe at exit and the time required to market the asset. JLL's Bid Intensity Index provides a forward-looking perspective on bidding activity, measuring real-time buyer activity across markets. The index shows that bidding dynamics are on the rise, driven by an increase in the number of unique capital sources bidding on transaction processes. However, while bidding pools are expanding, actual pricing competitiveness on individual transactions still lags peak 2021 levels by a notable margin[reference:19].

4.8 Lens 6: Operating and Execution Risk

The sixth lens separates owning a property from running a business inside it. Bali illustrates this best. A foreign-owned company can hold a right to build, but a villa or hotel's income depends on occupancy, brand, licences, and management—none of which the land right guarantees. The same applies to hospitality assets elsewhere.

Operating risk also includes building-level issues that never appear in a market report: deferred maintenance, service-charge shortfalls, planning compliance, and the quality of the managing agent. These are not abstract risks. They determine whether the income projected in the underwriting model is actually collected. McKinsey's research emphasises that operational levers—enhanced tenant experiences, energy retrofits, and AI-driven asset management—now lead returns. Leading capital allocators are acquiring embedded property management, property development, and asset-level execution capabilities to direct property-level operations and create value[reference:20].

5. Findings

5.1 Finding 1: Tenure Duration Has a Measurable Effect on Return

As demonstrated in Section 4.3, a flat 8% income yield delivers an IRR of 6.93% over 30 years, 7.81% over 50 years, and 8.00% over 99 years, assuming no residual value and no growth. The gap between 8.0% and 6.9% is approximately 107 basis points. This finding is significant because foreign-ownership rules in several of the markets analysed cap or shape the tenure available to foreign buyers. An investor who ignores tenure duration in cross-border comparison may systematically overvalue assets in markets with shorter permissible tenures.

5.2 Finding 2: Access Rules Differ by Market and by Asset Type

Commercial property is open to foreign buyers in some markets (Singapore, South Africa), restricted to designated areas or leasehold structures in others (Kenya, UAE, Thailand), and routed through specific corporate vehicles in others still (Bali). These are not peripheral considerations—they determine whether an investment is legally possible and what structure is required. The costs of nominee arrangements, special purpose vehicles, and cross-border holding structures are material and must be incorporated into return calculations before financial modelling begins.

5.3 Finding 3: Yield Is Only Meaningful Against the Local Cost of Capital

Nairobi's prime office yield of 8.5% sits approximately at the 91-day Treasury bill rate of 8.778% (October 2026), meaning the asset carries no visible premium over short-dated government paper before property risk is priced. This finding does not render Nairobi property uninvestable—rents can grow, capital values can change, and the instruments differ in risk and liquidity. It means the return must come from something other than the opening yield, and the investor should be able to articulate what.

5.4 Finding 4: Exit Costs Are Part of the Return

Withholding tax, capital gains tax, and transfer taxes vary widely and are often paid at different points in the holding cycle. FIRPTA withholding in the United States, at 15% of gross sale price, can exceed the actual tax due and must be modelled as a cash-flow item. Kenyan capital gains tax at 15% of net gain reduces exit proceeds. These frictions must be incorporated into net return calculations, not treated as afterthoughts.

5.5 Finding 5: Asset Selection Now Outweighs Market Selection

McKinsey's research demonstrates that asset selection accounted for approximately 70% of performance differentials in 2025, materially outweighing the effect of country- or property-type allocation decisions. This marks a meaningful increase from 2020 to 2022, when asset selection accounted for less than 50% of return dispersion[reference:21]. The implication for cross-border investment is that choosing the right asset within a market may matter more than choosing the right market. The framework's emphasis on asset-level due diligence—particularly the tenancy schedule, lease terms, and building quality—is therefore aligned with the empirical evidence.

5.6 Finding 6: Institutional Quality and Transparency Attract Capital

Wang's (2024) research demonstrates that a strong governance regime attracts higher foreign capital flows into real estate sectors, though different dimensions of governance have varying levels of influence. The effects of institutional quality on foreign real estate investment vary for developed and emerging economies and are also different for different modes of investment[reference:22]. The Journal of Real Estate Finance and Economics research confirms that the increased transparency of the global real estate industry has leveled the playing field for foreign property investors, with the underperformance of internationals disappearing in later years of the sample period[reference:23].

5.7 Finding 7: Comparable Data Is Limited

The eight markets do not publish rents, yields, and vacancy on identical definitions. This is not a reason to abandon comparison; it is a reason to be explicit about limitations. The framework requires that every data point be accompanied by its source, date, geographic scope, and definitional basis. Where comparable data is unavailable, the investor should state that limitation rather than substitute assumption for evidence.

6. Discussion and Implications

6.1 Implications for Different Investor Types

The framework's application depends on the investor's mandate. A core income investor prioritising stability may weight tenure duration and income quality more heavily. A value-add investor may tolerate shorter tenure and weaker covenants in exchange for higher going-in yield and repositioning potential. A development investor may prioritise access to land and planning regimes over existing income.

CBRE's 2026 Global Investor Intentions Survey found that value-add and core strategies were the most preferred globally, with investors planning to buy and sell more assets than last year. Residential assets are most sought after in North America and Europe, while Asia-Pacific investors prefer office assets and Latin American investors favour logistics facilities[reference:24].

Knight Frank's survey points to a return to the market for investors in Core strategies, with $37 billion of planned investment targeting Core assets (26% of all planned investment), as falling interest rates make Core increasingly attractive relative to fixed-income strategies. A further $33 billion is targeted to Core Plus (23%), $27 billion to Value Add (19%) and $40 billion to Opportunistic strategies (28%). Sixty-eight percent of respondents, collectively planning $94 billion of investment, stated they will consider joint ventures or capital partnering to make investments in 2026[reference:25].

This willingness to collaborate through joint ventures is significant for cross-border investors, as it provides a mechanism to access markets where local expertise and relationships are essential. The framework's sixth lens—operating and execution risk—becomes more manageable when a local partner with operational capabilities is involved.

6.2 Implications for Advisory Practice

For advisers and intermediaries, the framework provides a structured basis for client conversations. It shifts the discussion from "which market is best" to "which market fits your mandate." It requires that assumptions be documented, that legal constraints be resolved before financial modelling, and that currency exposure be quantified rather than assumed away.

6.3 The Evolving Nature of Market Risk

JLL's research notes that although geopolitical conflict and the potential for higher interest rates remain on investors' minds, they are not impairing capital markets' activity levels or functionality as investors increasingly view volatility as structural rather than episodic. The economic and fiscal outlook continues to be subject to volatility stemming from the conflict in Iran and the closure of the Strait of Hormuz. GDP growth forecasts have been revised down somewhat but are far from recessionary, with stable or stronger growth expected next year in most countries[reference:26].

This shift in investor psychology—from viewing volatility as an episodic disruption to viewing it as a structural condition—has implications for how the framework should be applied. Stress-testing scenarios should assume persistent volatility rather than a return to a stable baseline.

7. Limitations and Future Research

7.1 Limitations of This Study

This paper has several limitations. First, the legal entries rely partly on practitioner summaries rather than the statute itself; they should be confirmed with local counsel. Second, the illustrative calculations are not forecasts and exclude tax, acquisition costs, and rental growth. Third, the United States and United Kingdom access rules were not examined in this edition. Fourth, Abu Dhabi's ownership regime and the current status of Thai reform proposals were not verified. Fifth, the eight markets do not publish data on identical definitions, which limits direct comparison.

7.2 Future Research Directions

Future research could extend the framework in several directions: (a) developing quantitative scoring rubrics for each lens; (b) conducting empirical tests of whether yield differentials across markets compensate for measured differences in risk; (c) examining the effect of ESG compliance on cross-border investment decisions; and (d) investigating how currency hedging costs affect optimal market selection.

8. Conclusion

A defensible cross-border comparison starts with the investor, not the market. Establish what the investor can legally hold and for how long, normalise the income figures, set them against the local cost of capital, price the currency and the frictions, and only then ask whether the asset's income is secure. Each Murivest country article that follows applies this framework to a single market.

Murivest Group Ltd is a Nairobi-based commercial real estate advisory firm established in 2025 and operating on a mandate basis. Our primary ground data is in Kenya. Our research on the other seven markets is desk-based, drawn from official sources, regulators, law-firm guides and published market research, and it is labelled as such. We do not rank the eight markets, and nothing here is a recommendation to invest in any of them.

If you are assessing a commercial property requirement in Kenya or comparing it with other markets, you can arrange a briefing with the Murivest advisory team or write to capital@murivest.com. Murivest provides advisory services only, and does not pool capital.

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