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.
RequirementInternal Delegation Allowed?Third-Party Standard
ValuationYes, if conflicts are managedIndependent Valuer
SafekeepingYes, title verification onlyPrime Broker / Custodian
Cash MonitoringYes, if conflicts are managedFund 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