Mutual Funds (Amendment) Bill, 2011
Further to our Client Update of June 2011, the Cayman Islands Legislative Assembly is currently considering legislation intended to require registration of "master funds" in a "master/feeder" structure.
As the legislative process is ongoing the final form of the legislation has yet to be released, but it continues to be expected that the registration obligation will apply only to "master funds" which already have an existing CIMA registered "feeder fund" as part of the structure.
The procedure for registering the master fund continues to be expected to be straightforward, with no onerous additional reporting requirements. Closed ended private equity funds will not be subject to the new regime.
An earlier draft of the legislation included a 90 day period for registering existing master funds and, assuming this period remains unchanged, managers with master funds involved in their structures will need to move quickly to assess their position under the law and register where necessary.
It is anticipated that the legislation will be gazetted and come into force in the near future. We will, of course, let you have further details as soon as they are known.
If you require additional advice or assistance please contact your usual Maples contact.