We previously provided an
update that Bermuda's Investment Funds Act 2006
(IFA) had been amended with effect from 1 January
2020. The amendments were made with a six month transitionary
period for existing funds.
Given that we are now over half way through that period, it
seemed timely to provide a reminder that operators of such funds
should be considering whether they are now within scope of the IFA
or if your business needs to make any changes or take additional
steps in order to ensure continued compliance.
In addition to changes to the IFA, changes have been made to the
rules which were previously promulgated thereunder. These also need
to be considered as part of this exercise.