Private Funds & Mutual Funds - Regulatory Rule Segregation of Assets FAQs (2020-07-21)

Summary

This is a short CIMA notice from July 2020 announcing an update to its Frequently Asked Questions (FAQs) relating to the Regulatory Rules on Segregation of Assets that apply to registered private funds and regulated mutual funds. It does not introduce new rules itself but clarifies interpretation of the existing Segregation of Assets Rules issued earlier the same month.

• Prime brokerage or custody arrangements: The Segregation of Assets Rules for both Registered Private Funds and Regulated Mutual Funds do not prohibit arrangements where a custodian or sub-custodian holds client assets in a commingled client omnibus account together with other clients' assets, provided this is consistent with established and accepted industry practice.

This notice is informational in nature: it explains how CIMA interprets the existing segregation of assets requirements rather than creating new standalone obligations. Funds and their custodians should read it alongside the underlying Regulatory Rules to confirm their custodial arrangements remain compliant.

Applies to

registered private funds, regulated mutual funds, custodians/sub-custodians acting for private funds and mutual funds