Bahamas SMART Fund

SMART Funds are licensed under the Bahamas Investment Funds Act 2019 (which replaced the 2003 Act) and supervised by the Securities Commission of The Bahamas. Each fund follows an approved SMART Fund Model (SFM), a template that sets its investor limits, minimum investment, disclosure and audit requirements. Models range from small private vehicles for a handful of investors to structures for sophisticated investors; SFM 007, for example, is described as allowing up to 50 investors, each meeting a high minimum investment.

SMART Funds are typically licensed through a Bahamas-licensed investment fund administrator, which carries much of the regulatory responsibility. Some models permit investors to waive the annual audit unanimously, in which case the fund files periodic performance reports with the Commission instead. Certain models require only a short-form term sheet rather than a full offering memorandum.

Because obligations differ by model, operations teams should map requirements — audit, reporting frequency, investor limits — from the specific SFM rules. Model details are revised from time to time; check current requirements with Bahamas counsel.