31/08/2017 /

Comparison between Bahrain Exempt CIU and Bahrain PIU

No.

Category

Bahrain Exempt CIU

Bahrain PIU

1

Investors

Accredited Investors

 

‘Accredited Investors’ are investors who hold financial assets of US$1 million or more

High net worth individuals (HNWI) or institutional investors 

‘HNWI’ are investors who hold financial assets of US$25 million

2

Minimum Subscription

US$100,000

US$3 million

4

Offering Document

Prospectus must contain minimum information as stated in CBB Rulebook

Private Offering Document does not have any minimum disclosure requirement

4

Registration process

Registration process requires approvals from CBB. The process takes 2 to 3 months

Registration process is quick and fast. CBB approval can be granted with 10 business days from date of application

5

Appointment of Relevant persons

Needs to appoint

1) Operator/Fund Manager

2) Administrator, Registrar & Custodian

Fund Manager appointment is not mandatory instead Investment Advisory Committee (consist of any qualified personnel) can be appointed to oversee the investment activities of the fund. 

Operator, Administrator, Registrar & Custodian can be performed by one licensee

6

Audit and Review

Annual audit and half yearly review of the Fund is compulsory and have to be submitted within 4 months (annual audit) and 2 months (review) from the period end 

Annual audited financials of Fund Company must be submitted within 3 months of the financial year-end

No requirement for half yearly review of the Fund. Annual audit is compulsory with flexible deadline 

Annual audited financials of Fund Company must be submitted within 3 months of the financial year-end

7

CBB quarterly reporting

Standard quarterly statement would need to be prepared and submitted to CBB

Quarterly reporting requirements is less detailed

8

Investment External Valuation

Should be conducted by appropriately qualified valuators

No requirement for external investment valuation

9

Subsequent Material Changes

Once registered, any subsequent material changes to the corporate documents must be notified to the CBB within 10 working days prior to execution.

An updated copy of the documents must be made available to the CBB within 30 calendar days of executing such changes

No such requirement. Just have to notify CBB with no restrain on deadline and timings

10

Appointment of Relevant Person

Prior approval would need to be obtained from CBB before appointment of relevant person or any subsequent change

No such requirement. Only need to inform CBB for the appointment or change

11

Investment Limits

Fund needs to adhere to investment limits as per Prospectus and corporate documents of the fund

No requirement to include investment limits in the Private Offering Document

12

Dividends

All requests for distribution of dividends on holdings, must be approved in writing by the CBB prior to being announced

No such requirement

13

Liquidation

CIU Intending to liquidate must notify CBB of any such intent 

Upon finalizing the decision to liquidate, the operator must seek CBB's prior written approval to liquidate 

The request must be accompanied by BOD Resolution and EOGM resolution approving the liquidation 

Appoint Liquidator 

Inform the unitholders 

The whole process may take 6 months to 12 months

A PIU intending to liquidate must

  • notify the CBB of such intent and,
  • must seek legal advice 

Upon completion of the liquidation process, the operator of the PIU must notify the CBB of such fact

Note: 

Please note that this is just brief summary of the major differences between Bahrain Exempt CIU and Bahrain PIU. If you want any further information please visit CBB Rulebook Volume 7

http://www.complinet.com/cbb/display/display.html?rbid=3714&record_id=1

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