New filing and deadline for Cayman Islands private funds

Fund annual return form – deadline extended

A reminder that all private funds registered with the Cayman Islands Monetary Authority (CIMA) must submit a fund annual return (FAR) form.

For all private funds with a financial year end up to 31 March 2021 the date for filing the FAR form has been extended to 31 October 2021. Thereafter it will be due annually within six months of the private fund’s financial year end. For more information about the private funds FAR form please see our earlier client alert and our regulatory blog.

Related fund entities form – new filing

CIMA has just released another form to capture certain information about each private fund’s related fund entities, called the RFE form, which must be completed by private funds. This form is also due by 31 October 2021 for private funds with a financial year end up to 31 March 2021. Similarly to the FAR form, in subsequent years it will be due within 6 months of the private fund’s financial year end.

A related fund entity is an entity established by or on behalf of the promoter of the private fund which may account for certain regulatory, tax and other structuring needs of one or more groups of persons, which itself may not meet the definition of a private fund, and includes a parallel fund, an alternative investment vehicle or a co-investment vehicle. Holding vehicles, aggregators, proprietary vehicles and any other non-fund arrangements are not intended to be captured in the RFE form.

The RFE form can be found on CIMA’s REEFS online portal and the guide can be found on CIMA’s website here.

CRS compliance form

We also take this opportunity to remind you that the CRS compliance form for both the 2019 and 2020 periods must be filed by 15 September 2021 as noted in our regulatory blog earlier this year.

If you need assistance to complete the forms, or with any other matter, please contact your usual Harneys representative.