Two points of note for Cayman funds that are in scope. First, the six year record keeping period shall commence on the date when the relevant information is or should be reported to the TIA under the CRS Regulations. Second, a self-certification must be obtained upon account opening and validated as part of a fund's account opening procedures. The TIA notes that self-certifications will be one of its areas of focus for enforcement.

"The CRS Guidance Notes v2.1 dated 31 July 2017 has been published"