Funds Registration Notice (Interim Measures) (2020-02-20)

Summary

This is a short industry notice from the Cayman Islands Monetary Authority (CIMA) explaining a temporary process for registering certain mutual funds that had previously been exempted from registration under section 4(4) of the Mutual Funds Law (2020 Revision). Because these funds lost their exemption and became subject to registration, CIMA set out interim instructions for how to submit registration applications in the short window before its new electronic filing system (REEFS) became mandatory.

The notice applies to mutual funds that were previously exempt under section 4(4) of the Mutual Funds Law, and to the local service providers who assist them with regulatory filings.

• Before 1 March 2020: Applications must be emailed to CIMA's registrations address, including the application form, a CI$300 fee, constitutional documents, offering materials, confirmation of investor control rights, and optional administrator/auditor consent letters.
• From 1 March 2020 onward: All registration applications must instead be submitted through CIMA's REEFS portal using the applicable REEFS form, rather than by email. Any local service provider with REEFS access appointed to the fund can make the submission.

The notice is purely procedural/transitional, bridging the period until REEFS became the mandatory channel.

Key obligations

• Funds previously exempted under section 4(4) of the Mutual Funds Law (2020 Revision) seeking registration before 1 March 2020 must email CIMA (registrations@CIMA.ky) the Application Form (APP-101-22a), the CI$300 application fee, Certificate of Incorporation/Registration, Offering Memorandum/Summary of Terms/Marketing Material (as applicable), and confirmation that a majority of investors have power to appoint/remove the operator(s)
• Applicants may optionally include an Administrator's letter of consent and, if available, an Auditor's letter of consent as part of the email submission
• From 1 March 2020, all registration applications must be submitted via the REEFS portal using the applicable REEFS form instead of by email

Applies to

mutual funds previously exempted under section 4(4) of the Mutual Funds Law (2020 Revision), local service providers with REEFS access

Deadlines

• prior to 1 March 2020: Registration applications for funds previously exempted under section 4(4) may be submitted by email to CIMA using the interim process described
• 1 March 2020: Effective date after which all registration applications must be submitted via the REEFS portal using the applicable REEFS form