New Cayman Fund Reporting Requirements: What You Need to Know

Dec 8, 2024

2 min read

As year-end approaches, it’s critical for investment managers to stay updated on the latest reporting obligations to ensure compliance with the Cayman Islands Monetary Authority (CIMA) regulations. Here’s a breakdown of the recent updates to mutual and private fund reporting requirements under the Mutual Funds Act (MFA) and Private Funds Act (PFA):

Key Updates for Mutual Funds

New Fund Annual Return (FAR) Form Version 4.0
- Effective Date: Applicable for financial year-ends on or after June 30, 2020.
- Purpose: FAR Form 4.0 collects additional operating and financial information, aligned with the Mutual Funds (Annual Returns) (Amendment) Regulations, 2020.
- Submission Requirements:
  - Audited Financial Statements (AFS): Must be submitted within six months of the fund’s financial year-end.
  - FAR Form: Completed and submitted via CIMA’s electronic systems (E-Reporting or REEFS).
Transition Guidance:
- FAR Form 3.0 continues to apply for financial year-ends before June 30, 2020.
Submission Process:
- Local auditors, approved by CIMA, are responsible for filing both the FAR and audited financial statements using one of two systems:
  - E-Reporting: For older filings.
  - REEFS: For newer filings, offering enhanced electronic submission features.

Key Updates for Private Funds

Updated Private Fund FAR Form:
- For Year-Ends up to November 30, 2021: Use Form PFR-049-77.
- For Year-Ends on or after December 31, 2021: Use the updated Form PFR-049-77-02, which consolidates previous forms (e.g., RFE Form).
Submission Requirements:
- Audited Financial Statements (AFS): Required under Section 13(4) of the PFA.
- Private Fund FAR: Captures detailed operational, financial, and alternative investment vehicle data.
Submission Process:
- Operators may delegate submissions to a local Cayman Islands service provider, such as CIMA-approved audit firms, but retain ultimate responsibility for the accuracy of the filings.

Additional Compliance Considerations

Waivers/Extensions:
- Fund operators may apply for waivers, exemptions, or deadline extensions via CIMA’s REEFS system (mutual funds) or email (private funds). Fees apply for these requests.
Fee Payment:
- Submission of FAR forms requires the payment of a filing fee, due at the time of submission.

Why This Matters

These updates underscore the importance of accurate and timely reporting for funds domiciled in the Cayman Islands. Non-compliance with these updated requirements can result in penalties and reputational risks.