Sep 2021
Further to our recent Alert in respect of the upcoming deadline for filing Fund Annual Return Forms (FAR), please note that the Cayman Islands Monetary Authority (CIMA) has extended the filing deadline and issued a notice in respect of an additional form (the RFE Form) which is required to capture information on “related fund entities”. 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 parallel funds, alternative investment vehicles and co-investment vehicles.
Accordingly, private funds that are registered with CIMA with a 2020 financial year-end or year-end up to 31 March 2021 must submit both the FAR and the RFE Form via CIMA’s online REEFS portal by 31 October 2021 (originally due by 30 September 2021). For private funds with a financial year-end of 30 April 2021 and later, the filings must be completed within 6 months following the private fund’s year-end. For further details in respect of the RFE Form requirements, please see CIMA’s detailed Completion Guide covering the completion and submission of the RFE Form.
Accordingly, private funds that are registered with CIMA with a 2020 financial year-end or year-end up to 31 March 2021 must submit both the FAR and the RFE Form via CIMA’s online REEFS portal by 31 October 2021 (originally due by 30 September 2021). For
private funds with a financial year-end of 30 April 2021 and later, the filings must be completed within 6 months following the private fund’s year-end. For further details in respect of the RFE Form requirements, please see CIMA’s detailed Completion Guide covering the completion and submission of the RFE Form.
If you have any questions relating to the annual filing requirements or other continuing obligations of private funds, please contact any of the contacts below or your usual Conyers contact.