Regulatory Filing Extensions Update (2020-03-30)

Summary

This is a short follow-up notice from CIMA, dated 30 March 2020, building on an earlier notice issued 25 March 2020 about COVID-19-related regulatory filing extensions. It clarifies fee treatment for those extensions and relaxes two documentary requirements for funds during the pandemic disruption period.

Fee Treatment

CIMA confirms there are no separate fees for using the recently announced filing extensions, but all other normal regulatory fees still apply and remain payable when the actual filing is made. CIMA states it expects filings to be submitted on or before the extended deadlines unless it notifies filers otherwise, and points readers to a separate published list of all CIMA filing extensions.

Relaxed Documentary Requirements

• New fund registration/licensing: For new fund registrations/licensing under the Mutual Funds Law or Private Funds Law, CIMA will accept written confirmation from a fund operator, authorising the registered office or another service provider to file on the operator's behalf, instead of a notarised affidavit.
• Fund de-registration/cancellation: For fund de-registration/cancellation, CIMA will accept an uncertified resolution confirming the de-registration/cancellation date instead of a certified resolution.

Overall this is a temporary administrative relief measure tied to pandemic disruptions, not a change to substantive filing deadlines themselves, and CIMA notes it may make further adjustments as the pandemic situation develops.

Key obligations

• Filers must continue to pay all applicable regulatory filing fees (other than the extension fee, which is waived) at the time the relevant regulatory filing is made.
• Filers should submit regulatory filings on or before the applicable extended deadline unless CIMA otherwise notifies them.
• Operators of funds applying for registration/licensing under the Mutual Funds Law or Private Funds Law who wish to rely on this relief must provide written confirmation authorising the registered office or other service provider to file on their behalf, in lieu of a notarised affidavit.

Applies to

mutual funds, private funds, fund operators, licensees, registrants