Observations and Changes for REEFS Investment Strategy Selections (2023-11-08)

Summary

This is a CIMA general industry notice announcing changes to the drop-down list of "Investment Strategy" categories used in the REEFS portal for regulated Mutual Funds and Private Funds, effective 15 November 2023. The stated purpose is to improve statistical accuracy, particularly around identifying ESG and climate-focused funds, since CIMA observed that ESG is rarely selected as a strategy despite offering documents showing ESG considerations are incorporated.

• Removed: Some general categories are removed (e.g. "Private Equity," "Other").
• Added: Many new, more granular categories are added (e.g. Absolute Return, Private Credit, Infrastructure, Secondaries).
• Renamed/Amended: Others are renamed or amended (e.g. Fixed Income/Debt, Crypto/Digital/Virtual Assets-related).

The notice applies to all regulated Mutual Funds and Private Funds that submit fund registration applications or Fund Annual Return (FAR) filings via REEFS. It directs funds to select ESG as their Primary Investment Strategy if ESG is their core focus, or as a Secondary Investment Strategy if ESG considerations are material but non-core, even if not previously reflected in prior REEFS filings.

• Manual submissions: The revised list has already been available for manual fund registration submissions since early 2023, and only these revised selections may be used for manual submissions.
• From 15 November 2023: All fund registration applications, including automated/bot submissions, must use the revised list.
• FAR filings: FAR filings for financial years ending 31 December 2023 or later must also use the revised Investment Strategy categories.

Key obligations

• Funds for which ESG is the core focus must select ESG as the Primary Investment Strategy in REEFS filings.
• Funds with material but non-core ESG considerations must select ESG as the Secondary Investment Strategy in REEFS filings.
• On or after 15 November 2023, all fund registration applications submitted via REEFS, including bot (automated) submissions, must use the revised Investment Strategy selections list.
• FAR submissions for financial years ending 31 December 2023 or thereafter must use the revised Investment Strategy list.
• Manual fund registration applications must use only the revised Investment Strategy selections (in effect since early 2023).

Applies to

Mutual Funds, Private Funds

Deadlines

• 15 November 2023: Effective date for the changes to the Investment Strategy selections in REEFS; from this date all fund registration applications, including bot submissions, must use the revised list.
• financial years ending 31 December 2023 or thereafter: FAR filings for these financial years must use the revised Investment Strategy list.