Generally, under the Common Reporting Standard
(CRS) investment managers and advisers are
classified as 'Investment Entities' and are 'Reporting
Financial Institutions' for CRS purposes. As a result, they
have certain obligations to fulfil under Bermuda CRS legislation.
This differs from the position under FATCA which allows for most
investment managers and advisers to be classified as
'Non-Reporting Financial Institutions'.
Under the Bermuda-US Inter-Governmental Agreement on FATCA, an
Investment Entity established in Bermuda that is a Financial
Institution solely because it (i) renders
investment advice to, and acts on behalf of, or (ii) manages
portfolios for, and acts on behalf of, a customer for the purposes
of investing, managing, or administering funds deposited in the
name of the customer with a Financial Institution (other than a
Non- participating Financial Institution) is a Non-Reporting
Bermuda Financial Institution treated as a certified
