Cross-border comparison
| Module | Cayman | Hong Kong | BVI | Singapore |
|---|---|---|---|---|
| Main regulator | CIMA | SFC | FSC | MAS; ACRA for VCC corporate matters |
| Core perimeter | Mutual fund / private fund | Public authorization plus OFC/other vehicle | Open-ended categories; closed-ended PIF | CIS offer, VCC vehicle and manager licence |
| Vehicle vs fund status | Separate analyses | OFC registration coordinates with incorporation | Formation and recognition/registration differ | VCC registration is not manager licensing |
| Key governance | Operator | Directors, manager, custodian | Directors/GP and required functionaries | Directors, fund manager, secretary, applicable custodian |
| NAV sources | CIMA rules, law, offering document | OFC/product codes and offering document | Fund rules, PIF rules and policy | CIS Code, VCC and offering documents |
| Annual reporting | AFS + FAR generally six months after FYE | OFC annual report; no conventional CR annual return | Category-specific audit; separate MFAR | Audit; AGM six months and annual return seven months |
| AML scope | Fund and financial-services status | Determine by licensed/associated entity | Determine fund, licensee or approved-manager scope | Apply the MAS notice for the regulated person |
| CRS authority | DITC | IRD | International tax authority | IRAS |
Four recurring traps
- Legal form is not regulatory category. Keep
entity_typeandregulatory_statusas separate fields. - Administrator is not investment manager. Contracts, permissions and translations must keep the operating and investment functions separate.
- An annual return is not an annual report. Cayman FAR, Hong Kong OFC reporting and Singapore VCC filings are distinct deliverables.
- Fund registration does not determine FATCA/CRS classification. Keep a separate entity-classification analysis and evidence trail.
A minimum master record holds legal name and number, vehicle, regulatory category, structure relationships, providers, AML officers, FYE, valuation cycle, dealing terms, reporting-FI classification, portal owner, obligation ID, due date, status and evidence link.