The Cayman Islands Monetary Authority (“CIMA”) has issued the new Form MF4 for the registration of master funds. The Mutual Funds (Amendment) Bill, 2011, published with the Extraordinary Gazette No. 113 dated December 22, 2011, now requires most master funds to be registered with CIMA.
In June 2011, the Cayman Islands government announced a proposal to amend the Mutual Funds Law (“2009 Revision”) to require Cayman Islands master funds that have regulated feeder funds as part of their structure to be subject to new registration and filing requirements. On December 5, 2011, a revised version of the bill was passed by the Legislative Assembly of the Cayman Islands.
Not all master funds will require registration. This new registration requirement will apply to Cayman Islands incorporated open-ended master funds that have one or more Cayman Islands regulated feeder funds as part of their structure. Closed ended funds, master funds incorporated outside the Cayman Islands, or master funds without Cayman Islands regulated feeder funds will not be affected by these changes.
Registered master funds will have to meet several obligations which include: payment of an annual fee of approximately $3,000 to the CIMA; filing of an annual audited financial statements signed off by a CIMA approved auditor along with a Fund Annual Report (“FAR”) within six months of the fund’s year end; and provide CIMA with a copy of the fund’s offering memorandum or file the new registration form (Form MF4) which discloses certain required information.
For fund structures existing at December 22, 2011, there is a 90 day period for registration. For newly formed master funds, registration will be required before business commences.