Hi there,
Today, we write you under a new name and identity – Suntera Fund Services. Nearly two years after Suntera Global acquired Socium Fund Services, we have officially rebranded to align with the global brand. This marks a significant milestone as we continue to provide seamless, localized fund servicing solutions as part of a global team.
Now, as part of a larger organization with global servicing capabilities, we are excited to share insights more regularly on private fund-related developments in the Cayman Islands and the U.S. This edition features updates from Korie Drummond, Director of Fund Services – Cayman Islands, along with a guest article from Trillium on FinCEN’s Final Rule and its impact on investment advisers.
Lastly, we invite you to join us for cocktails on October 29th at Annie Moore’s in New York to celebrate our rebrand and reconnect with colleagues, clients and friends.
Best regards,
Suntera Fund Services
Guest Commentary
FinCEN Finalizes Rule for Adviser AML Compliance
By Trillium
On August 28, 2024, FinCen issued a Final Rule to address and prevent money laundering, terrorist financing, and other illicit finance activity through the investment adviser industry. The Final Rule, set to go into effect on January 1, 2026, will have significant implications on both Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs). Specifically, RIAs and ERAs will need to:
For further information, please read Trillium’s article here.
Cayman Corner
On July 31, 2024, major changes to the Cayman Islands beneficial ownership reporting regime (BORR) came into effect. These are the most significant changes made since 2017, when the BORR was enacted to comply with international standards to combat money laundering, tax evasion, and terrorist financing. The Ministry of Finance Services and Commerce confirmed the enforcement of the new requirements will go into effect on January 1, 2025.
What does this mean for Cayman Islands-regulated private funds?
The Beneficial Ownership Transparency Act, 2023 (BOTA) expands the scope of the BORR to include Cayman Islands companies, limited liability companies, limited liability partnerships, foundation companies, and exempted limited partnerships. Entities previously exempt that now fall in scope must identify their registrable beneficial owners (RBOs) and provide details to their CIMA-licensed corporate service provider or administrator unless an alternative route to compliance is available.
The Ministry of Financial Services & Commerce has issued Guidance Notes on Complying with the Beneficial Ownership Obligations in the Cayman Islands, available here.
Read our briefing note here, and reach out to Korie Drummond, Director of Fund Services, Cayman Islands, with any questions.
Out and About
Our team connected with industry partners, clients and fund managers at several conferences and events this past quarter.
Private Debt Investor Forum
Suntera Fund Services Co-Managing Director of the Americas, Beth Mueller, attended the Private Debt Investor New York Forum in New York last month. It was a great event to better understand what others in the private credit space are experiencing in this dynamic time. Panelists discussed topics including deal opportunities and the risk landscape, how the macroeconomic changes are shifting the North American private debt landscape, and investment and allocation strategies in private debt.
Sadis & Goldberg Private Funds Forum
Matthew Reynolds, Suntera Fund Services Head of Business Development for the Americas, attended the Sadis & Goldberg Private Funds Forum in the Bahamas. During this exclusive event, the most pressing topics pertaining to the private funds industry were discussed, including the impact FinCEN’s final rule will have on registered investment advisers, discussions on fee structure trends, the private funds rule and the impact on the industry, and other topics.
LSTA Annual Conference
Suntera Fund Services Head of Loan Agency and Loan Administration Harvey Tian, attended the LSTA annual conference in New York last month. This one-day event is the conference to attend for the private credit industry. Everything from the economy to geopolitical trends to the loan syndication market was discussed.
Upcoming Event: Suntera Fund Services Cocktail Event
Join the Suntera Fund Services team on October 29th, at Annie Moore’s in New York to connect and celebrate our rebrand and expanded offering. To learn more about the event and to register, please click this link. We look forward to seeing you there!
Thought Leadership
Keeping up with Private Credit's Evolution
Published in Private Debt Investor US Report 2024
Michael Von Bevern and Harvey Tian spoke with Private Debt
Investor about the dynamic private credit industry and how the complexity of new structures has caused administration challenges requiring bespoke solutions from service providers. Read the article for further insight.
Introduction to Rated Note Feeder Funds
Michael Von Bevern discusses the mechanics and benefits of rated note feeder funds in a recent article.
Other Newsworthy Updates
Awards
Suntera Fund Services has been shortlisted as a finalist in the Fund Administration of the Year category for the Alternative Credit Investor awards. The winners will be announced on November 6th in London.
Suntera Global News
Real estate is evolving rapidly, driven by technology, sustainability, and changing investor behaviors. In our 'Real Estate from a New Perspective' series, our Funds experts explore the key drivers shaping the real estate investment space. Gain further perspective by clicking the links below.
Real Estate from a New Perspective series: Tokenisation: Virtual real(ity) estate
Real Estate from a New Perspective series: Real Estate: Ripping up the rule book
Real Estate from a New Perspective series: Real estate through a Sharia lens
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