Private Funds Act Update - June 2021

An update on the Private Funds Act annual return requirements and filing deadlines.

CIMA Requirement to File Annual Return Forms

Private funds regulated by CIMA are required to file a Fund Annual Return (“FAR”) in each year with CIMA. The FAR must be filed with CIMA within six months of the private fund’s financial year end. The private fund may be subject to regulatory fines and will not be in good standing with CIMA for failure to file the FAR on time.

A template FAR Form is expected to be released by CIMA in June 2021.

The FAR filing fee is US$365.85. If the private fund has an alternative investment vehicle (“AIV”) and/or sub-fund there is an additional filing fee of US$182.93 for each vehicle (up to 25 vehicles).

Private funds that have not received any capital contributions from investors are not required to file a FAR but must file a declaration with CIMA confirming the same.

Private Funds Act – Audited Accounts Filing Deadline Extension 

Private funds will a 31 December 2020 year end have been granted a filing extension from 30 June 2021 to 30 September 2021.

Mutual funds do not have an extension to file their FAR (and so a regulated mutual fund with a financial year end of 31 December 2020 is still required to file its FAR with CIMA by 30 June 2021).