Private Funds and the Cayman Islands Fund Annual Return Deadline
The Maples Group provides Fund Annual Return (“FAR”) completion and filing services to ensure filings are made on time and alleviate the operational burden and cost to fund advisers. This service includes FAR preparation, FAR filing and coordinating regulator fee payments.
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Cayman Islands domiciled closed-ended investment funds that are registered as private funds with the Cayman Islands Monetary Authority (“CIMA”) are subject to a filing requirement through their online portal REEFS, which includes informational data encompassing general, operating, related fund entity and financial information, as well as submission of annual audited financial statements and an operator declaration.
What is the FAR?
The FAR is a Microsoft Excel-based tool through which CIMA captures general, operating and financial information relating to registered funds. It is required to be filed annually alongside the audited financial statements within six months after the financial year-end. While the local Cayman Islands auditor or other designated person must file the FAR on behalf of the fund, the fund operator, which includes the directors, trustee or general partner depending on how the fund is structured, ultimately is responsible for completing the FAR.
This filing is an annual requirement, with funds that launch operations during the first half of their fiscal year needing to report no later than six months after the end of that first part-financial year. Declarations and waivers are required for closed-ended funds not filing, whether due to a fund not yet drawing down capital from investors for investment purposes or where reporting an approved extended period (up to 18 months for first and last reporting periods).
How Maples Group Can Help You with the Process
To alleviate the operational burden as it relates to FAR completion, the Maples Group’s Accounting, Tax & Agency Services team can provide FAR services that include on-boarding, assistance with FAR preparation, and providing ongoing feedback and consultation on completing the FAR. The team can also submit the approved FAR directly to CIMA through the portal or provide it to the fund’s auditor for filing. A stand-alone filing service is also available if assistance with preparation is not required.
Our experienced team has a deep understanding of the FAR requirements and overall financial statement preparation process and is committed to providing a high quality and timely service. This approach ensures that a fund is in compliance, while freeing up the fund operator to focus on its core management functions. (The costs of this service, being of a regulatory / compliance nature, routinely are characterized as a fund expense under fund documents).
As a market leader in the provision of legal, fiduciary, fund, regulatory and compliance and entity formation and management services, the Maples Group is committed to supporting our clients’ efforts to comply with the Private Funds Act regime.
For more information on FAR filing, get in touch with our Accounting, Tax, and Agency Services team.