Update: Importance of a Comprehensive Crisis Management Framework and CIMA's Commitment to Implementation (2026-03-02)

Summary

This is a Supervisory Information Circular from CIMA providing a status update on its ongoing work to build a crisis management framework for the Cayman Islands financial sector, following an earlier circular issued in January 2025. It does not itself impose new binding rules but reports on the progress of consultations toward a Rule and Statement of Guidance (RSOG) on Recovery Planning.

Background and Scope Changes

• Original proposal: CIMA originally proposed a combined Recovery and Resolution Planning RSOG in January 2025.
• Revised approach: After consultation feedback and an IMF technical assistance mission in March 2025, CIMA decided to separate Recovery Planning from Resolution Planning and focus first on Recovery Planning.
• Standalone consultation: A revised, standalone RSOG on Recovery Planning was issued for consultation in November 2025, with the consultation feedback deadline set at 30 January 2026.
• Scope: The scope of this proposed RSOG is narrowed to deposit-taking institutions (banks, including credit unions and development banks), aligning with CIMA's existing Regulatory Policy on Domestic Systemically Important Deposit Taking Institutions.

Forward Outlook

• Feedback review: CIMA states it will review consultation feedback during Q1 2026 and intends to publish a final RSOG.
• Effective date: The final RSOG is expected to become effective within twelve months of being gazetted.
• Future requirements: Once finalized, this RSOG will impose recovery planning requirements on in-scope deposit-taking institutions, though those requirements are not yet in force.
• Further expansion: CIMA also signals intent to eventually expand recovery planning requirements beyond deposit-taking institutions.

As of this circular, no new binding obligations take effect; it is a progress update and forward outlook.

Key obligations

• Deposit-taking institutions (banks, credit unions, development banks) should anticipate future compliance obligations once the final Recovery Planning RSOG is gazetted and becomes effective
• Entities that participated in the November 2025 consultation were required to submit feedback on the proposed RSOG by 30 January 2026 (a deadline that has now passed)

Applies to

deposit-taking institutions, banks, credit unions, development banks

Deadlines

• 30 January 2026: Deadline for stakeholder feedback on the proposed Rule and Statement of Guidance (RSOG) on Recovery Planning issued for consultation in November 2025
• within twelve (12) months of being gazetted: Expected timeframe for the final RSOG on Recovery Planning to become effective once gazetted, following finalization anticipated in Q1 2026