In addition to the new Private Fund Annual Return (“FAR”), Private Funds are also required to file an additional filing to capture information for Related Fund Entities (“RFE”).
The Private Funds (Annual Returns) Regulations, as Revised, defines a “related fund entity”, in relation to a private fund, as an entity established by or on behalf of the promoter of the private fund which may account for certain regulatory, tax and other structuring needs of one or more groups of persons, which itself may not meet the definition of a private fund, and includes —
a parallel fund;
an alternative investment vehicle; or
a co-investment vehicle;
The RFE filing form requires the following information, amongst other things –
Number of RFE entities
For each RFE, the name, type of related fund, country of domicile, regulator, regulatory certificate (if regulated)
Confirmation if the RFE has issued a digital representation of its investment interest within the reporting period
Confirmation if there have been any regulatory investigations in respect the RFE within the reporting period
A Private Fund must submit both the FAR (along with the declaration) and RFE form on the REEFS portal in order to satisfy the reporting requirements for a given reporting period. The filing deadline for the RFE form is the same as for the FAR form for the Private Fund.
The Cayman Islands Monetary Authority (“CIMA”) has issued a completion guide for the RFE form labelled Related Fund Entity Information (RFE-050-77) and may be accessed here. CIMA also issued a notice on 1 September 2021 advising that the RFE form is available on their REEFS portal, see more details here.
If you have any questions or would like to discuss this further, please get in touch with your usual IMS contact.