Passed in 2020, the Private Funds Act (PFA) brought thousands of previously unregulated closed-ended vehicles (PE, VC, Real Estate) under CIMA's supervision.
The Core Pillars of PFA Compliance
If a vehicle qualifies as a private fund, it must adhere to four strict operational pillars:
- Valuation: Asset valuations must be conducted at least annually. If performed internally, the valuation process must be independent from the portfolio management function.
- Safekeeping of Assets: A custodian must hold title to custodial assets and verify ownership of non-custodial assets.
- Cash Monitoring: Cash flows must be monitored, and investor payments must be tracked.
- Securities Identification: Maintenance of a record of title for securities.
| Requirement | Internal Delegation Allowed? | Third-Party Standard |
|---|---|---|
| Valuation | Yes, if conflicts are managed | Independent Valuer |
| Safekeeping | Yes, title verification only | Prime Broker / Custodian |
| Cash Monitoring | Yes, if conflicts are managed | Fund Administrator |
Registration Timing
A private fund must submit its registration application to CIMA within 21 days after accepting capital commitments, and it cannot accept capital contributions until it is registered.
Check Audit Requirements