How to Choose a Cayman Fund Platform: The Due Diligence Questions That Matter
Most managers choose a fund platform on price and speed, then discover the decisions that matter after their investors have subscribed: who actually controls the board, what the platform fee leaves out, whose AML programme an inspector will test, and what it takes to leave. Allocators will ask those questions during operational due diligence. A manager should ask them first, and get the answers in writing.
"The platform you choose becomes part of your due diligence file. Every allocator who reviews your fund is also reviewing the platform's governance, its controls and its exit terms, whether you asked the questions or not."David Lloyd, Chief Executive Officer at CV5 Capital
Why the Choice Matters More Than It Looks
On a segregated portfolio company platform, the manager's fund is a segregated portfolio of a company the platform controls. The board, the AML officers, the service provider contracts and the regulatory filings sit at the level of that company. That arrangement is what makes a platform launch faster and, below a certain scale, cheaper. It also means the platform's quality becomes the manager's quality in the eyes of every allocator.
The questions below are grouped by the areas allocators test. They apply to any platform, including ours. For the wider comparison, see our analysis of platform versus standalone launch and what allocators actually prefer.
1. Regulatory Standing and Structure
- Who is regulated, and how? Ask to see the platform entity's CIMA registration and the fund company's registration, and confirm how each new segregated portfolio is notified to or registered with CIMA.
- Which regime will your portfolio fall under? Open-ended and closed-ended strategies sit under different CIMA regimes; see Mutual Funds Act or Private Funds Act.
- What do the articles say about cross-liability? Under the Companies Act, segregated portfolio assets are protected from the creditors of other portfolios. A liability attributable to a portfolio can, however, reach the company's general assets once that portfolio's own assets are exhausted, unless the articles specifically prohibit it. Ask what the articles provide.
- How many portfolios share the company, and how different are they? A large number of unrelated strategies under one company is a question allocators will ask about.
For the structural background, see the Cayman segregated portfolio company guide and how ringfencing holds up in practice.
2. Governance
- Who sits on the board, and how independent are they? Names, residency, other appointments and time commitment.
- How does the board oversee individual portfolios? Ask for a redacted board pack and the meeting calendar. CIMA's Corporate Governance Rule sets the baseline the board is measured against.
- How are conflicts between portfolios handled? Shared counterparties, shared service providers and allocation of company-level costs.
- Can the board remove the manager, and on what grounds? This is the clause most managers never read before signing.
3. AML and Sanctions
- Who are the AMLCO, MLRO and deputy MLRO? Named individuals, not just a firm.
- Is there a risk assessment for each portfolio, or only for the company? CIMA's AML Rule FAQs expect risks specific to the regulated entity to be identified, and independent audits to test each fund's own programme.
- What is the independent audit cycle and when is the next audit? CIMA's FAQs set no fixed frequency, but require at least one external audit in every three cycles.
- Who answers a CIMA document request, and how fast? See what a CIMA AML desk-based review asks for.
4. Service Providers
- Which administrator, auditor, bank and custodian does the platform use? Are they mandatory or can you propose alternatives?
- Who negotiated the terms, and are portfolio-level minimums spread across the platform?
- Who owns the relationship if a provider fails or exits?
- For digital asset strategies: which exchange and custody arrangements are already in place, and how are accounts opened in the name of the portfolio? See exchange and custody controls for ODD.
5. Economics
- What exactly does the platform fee cover? Directors, AML programme, valuation framework, documentation and regulatory filings, or only some of these?
- What is charged to the portfolio rather than to the manager? This drives the expense ratio allocators will calculate.
- What are the minimums, and when do they apply?
- What does it cost to leave? Termination fees, notice periods and the costs of transferring assets.
For the cost categories in detail, see the true cost of running a Cayman fund.
6. Control and Portability
- Who retains investment discretion, the strategy, the brand and the investor relationships? These should sit with the manager. See platform fund, manager-owned strategy.
- What is the exit route if you outgrow the platform? A segregated portfolio is not a separate legal person and a segregated portfolio company cannot take part in a Cayman statutory merger, so leaving usually means a new fund and a transfer of assets. Ask how the platform supports that, on what notice and at what cost. See moving from a platform segregated portfolio to a standalone fund.
- Can you add a second portfolio or share class without re-papering everything? See launching multiple funds under one platform.
7. Documents to Ask to See
A platform that is confident in its infrastructure should share these, redacted where necessary, before engagement:
| Document | What it tells you |
|---|---|
| Platform compliance manual and policies | Whether AML, sanctions, conflicts, valuation and personal dealing are documented and maintained. |
| Valuation policy | Pricing sources, escalation and board oversight; see fund valuation policy. |
| Template offering supplement and subscription documents | How your terms will be expressed, and how much is fixed. |
| Platform or investment management agreement | Fees, termination, removal rights and exit mechanics. |
| Sample board pack and minutes | Whether oversight is substantive. |
| Most recent AML audit summary | Findings and remediation status. |
| Launch timetable and checklist | Realistic sequencing, including CIMA filings. |
Red Flags
- No named individuals for directors or AML officers.
- A fee quote that does not itemise what is included.
- Reluctance to share the platform agreement before commitment.
- No clear answer on exit mechanics or cost.
- Launch timelines quoted without reference to CIMA filings or onboarding with banks and custodians.
- Claims that the platform guarantees allocator approval or capital raising.
CV5 Insight: The best test of a platform is whether its answers to these questions would survive an allocator's ODD questionnaire without editing.
How CV5 Capital Answers These Questions
CV5 Capital operates CV5 SPC for traditional strategies and CV5 Digital SPC for digital asset strategies. A new segregated portfolio typically launches in three to four weeks, and each new portfolio is registered with CIMA through a filing. The platform provides the board, the AML/CFT/CPF compliance programme, the valuation policy framework and the operating documentation. Managers retain investment discretion, strategy, brand and the investor relationship, and investors subscribe into the relevant segregated portfolio, not into CV5 Capital.
We would rather answer every question above before launch than have a manager meet them for the first time in an allocator's review.
Conclusion
Choosing a platform is a governance decision with a commercial consequence, not a procurement exercise. The manager who asks these questions before signing will be able to answer the same questions from allocators with documents rather than reassurance.
Ask Us the Questions
Speak with CV5 Capital about launching a Cayman hedge fund or digital asset fund through a regulated platform, and request the documents listed above as part of that conversation.
Hedge Fund QuestionnaireDigital Asset Fund QuestionnaireFrequently Asked Questions
What is a Cayman fund platform?
A regulated structure, usually a segregated portfolio company, under which a manager launches its fund as a segregated portfolio using the platform's existing board, compliance programme, service providers and documentation, rather than building a standalone fund.
Are segregated portfolios fully protected from each other?
The Companies Act protects each portfolio's assets from the creditors of other portfolios. A portfolio's creditors can, however, have recourse to the company's general assets after that portfolio's own assets are exhausted, unless the articles prohibit it, so the articles should be checked.
Who owns the strategy on a platform?
On a well-structured platform the manager retains the strategy, investment discretion, brand and investor relationships. The platform provides governance and operating infrastructure. The platform agreement should say so expressly.
Can I leave a platform later?
Yes, but not by converting the portfolio into a company, because a segregated portfolio is not a separate legal person. Leaving usually involves launching a standalone fund and transferring assets, so the exit terms should be agreed before launch.
Does a platform guarantee allocator approval?
No. A platform provides the governance and operating infrastructure allocators expect to see. Each allocator still assesses the strategy, team and track record separately.
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