Bermuda Investment Funds’ Developments
The Investment Funds Act 2006 (IFA) was amended by the Investment Funds Amendment Act 2019 (IFA Revision) and became operative on 1 January 2020. The IFA Revision introduced some important changes to investment fund regulation in Bermuda with the intention of further strengthening the regulatory framework in Bermuda for funds. These changes are intended to address economic substance for collective investment vehicles which previously did not require any registration under the IFA or regulation by the Bermuda Monetary Authority (BMA) pursuant to the IFA. Consequently, closed-ended Bermuda investment funds and overseas investment funds which are managed or carry on promotion in or from within Bermuda are now required to seek registration or designation with the BMA during a transition period of 6 months. Our Memorandum considers these new categories together with some supplemental changes under the IFA Revision.