Bermuda Reporting Financial Institutions (RFI) must report to the Bermuda Monetary Authority (BMA) by 31 August  2017. The BMA will in turn automatically exchange information with reportable jurisdictions during September, 2017.

The Guidance is not law but aims to facilitate compliance with Bermuda’s CRS law. Here are some notable mentions on the Guidance from a trust perspective.

The Guidance confirms that Bermuda resident RFIs must notify the BMA by way of an information report by 14 July 2017.  Notification is a one-off process. Thereafter, financial institutions must notify the BMA by 30 April following the reportable period in which the financial institution becomes an RFI.

Financial institutions that do not maintain financial accounts have no reporting obligations. RFIs with no reportable accounts must nevertheless complete the notification requirement. Most Bermuda registered pension funds will not be RFIs. Certain other pension funds must submit an annual declaration to the BMA in order not to be classified as an RFI. Otherwise, unlike certain other jurisdictions, Bermuda’s non-reporting financial institutions are not required to notify.

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