A CLOser Look At Regulatory Developments - March 2021

INTRODUCTION

There have been several new regulatory developments in the Cayman Islands, Ireland and Delaware over the past few months that potentially impact CLO transactions. The Maples Group is proactively monitoring and addressing these regulatory developments to ensure that our clients' CLO transactions are compliant with new requirements. This CLOser Look focuses on the implications of the recent regulatory developments for the CLO market in particular, and provides a gateway to the more general updates that have been issued by the Maples Group.

CAYMAN ISLANDS

ECONOMIC SUBSTANCE

The Department for International Tax Cooperation ("DITC") has recently extended the reporting deadlines for entities due to file an Economic Substance return (an "ES Return"). The deadline for the first submission for entities providing evidence that they are tax resident overseas is 28 February 2021 for those with a financial year ending up to 29 February 2020. Otherwise, the