The purpose of this page is to explain the application process for a CIS Administrator.
This section sets out:
- What a CIS Administrator is and what this regulated activity would allow you to do
- Authorisation Process
- Capital Requirements
- Additional Information
What is a CIS Administrator and what would this regulated activity allow you to do?
A CIS Administrator provides administration services to collective investment schemes. CIS Administration is a regulated activity under the Financial Services Act 2019. A CIS administration permission will allow a firm to carry out the below services to collective investment schemes.
- Fund accounting: Maintain principal books and records, calculate, and publish Net Assets Values for funds under administration. The administrator will also calculate and arrange for the disbursement of fees, costs and expenses in accordance with the fund’s private placement memorandum.
- Registrar, transfer agency and client services: Receive and distribute monies, and process and record relevant details in the share register and communicate the same to fund investors. Establish banking and/or custodian relations for the funds under administration and account for the receipt of monies invested.
- Financial accounting: Maintain the fund’s financial and accounting records, arrange for the preparation of the annual financial statements. The administrator will also appoint, correspond and deal with, on a day-to-day basis, the auditors of the funds under administration. They will also arrange for quarterly reports to investors if applicable.
- Compliance: Review, monitor and ensure continued compliance with applicable legislation for funds under administration and to ensure that only fit and proper persons/legal entities are permitted to form, maintain and/or invest in funds under administration. Administrators will review money wired in or out of the fund’s bank accounts and compliance to Gibraltar Anti Money Laundering requirements. The Administrator will also assist funds in obtaining listing on stock exchanges and ensure ongoing compliance with the same. This is also the responsibility of the Directors of the fund.
CIS Administrators are required to have a service agreement with funds that set out the agreed services that the CIS administrator will provide to the fund, the fees to be charged and termination provisions.
Fund structures such as Experienced Investor Funds require an administrator.
Following successful completion of the pre-application process, applicants should submit an application in line with the Staged Application for Authorisation Approach.
Initially, the applicant will only submit the Stage 1 application information - it is important that only Stage 1 information is provided at the outset of the application process.
The GFSC will communicate to the applicant that the application can progress to the next stage once the GFSC is satisfied with the content provided at the current stage. The applicant will then be invited to submit the further information required at the next stage of the application process.
Please request cloud access from the GFSC to submit the information requested, via e-mail to [email protected], stating in the subject field: ‘Name of Applicant – Application’. Paper copies are not required unless indicated by the team.
Please note that we accept signed signature copies sent via e-mail and electronic signatures, which must originate from the Regulated Firm /Applicant’s domain.
Stage 1 - Business Model, Capital & Key Individuals
The following is to be submitted for Stage 1:
On receipt of the application fee and Stage 1 documents, the GFSC will confirm the GFSC Supervisor who has been assigned to assess the application for authorisation.
Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 1 will be communicated to the applicant during Stage 1.
When the GFSC is satisfied with all the responses and information/documentation received, the GFSC will inform the applicant that its application can progress to Stage 2.
Stage 2 - Risk Management, IT Systems, Corporate Governance & Financial Crime
The following is to be submitted for Stage 2:
- Stage 2 of the General Comprehensive Business Plan (not including Stage 3);
- Documentation and information including, but not limited to:
- Corporate Governance and control
- Business Continuity Management Plan
- IT infrastructure, Cyber and systems including outsourcing arrangements
- Operational & Outsourcing Risk including material outsourcing arrangements
- Systems controls & Risk Management
- Financial Crime controls, compliance with Anti-Money Laundering/Combating the Financing of Terrorism requirements (as applicable)
- Risk Methodology and framework policy documents
- Risk Register & controls
- Disaster Recovery Plan
- Updated business plan, if required.
Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 2 will be communicated to the applicant during Stage 2.
When the GFSC is satisfied with all the responses and information/documentation received from an applicant, the GFSC will inform the applicant that its application can progress to Stage 3.
Stage 3 - Conduct of Business, Non-Financial Resource, Policies & Procedures
The following is to be submitted for Stage 3:
- Stage 3 of the General Comprehensive Business Plan;
- Documentation and information including, but not limited to:
- Non-financial resources
- Compliance structure
- Conduct of Business (Full Conduct Risk Framework documents)
- Detail of KPIs
- Consumer Duty compliance (as applicable)
- Operational Resilience compliance (as applicable)
- Remuneration Policy
- Conflict of Interest Policy
- Conflict of Interest Register
- Liquidity/solvency policies
- Internal Audit Plan
- Complaints Handling Policy
- Terms of Reference of the Board, Board sub-committees, Risk Committee and/or Audit Committee, Underwriting/Pricing committees, as applicable
- Audit, accounting, and banking arrangements
- Professional Indemnity Insurance
- Contracts with parties to whom material operational functions are outsourced
- Completed and signed Regulated Individual Forms and Non-Executive Director Forms
- Mobilisation Plan (if applicable).
When the GFSC is satisfied with the Stage 3 responses and information, the application will move to a GFSC decision for authorisation.
The minimum regulatory capital is £10,000. The GFSC may however require that a firm hold higher amounts of capital than the stipulated minimum.