undervalue, shall be voidable at the insistence of an eligible creditor thereby prejudiced". The burden of proof is borne by the creditor applying to set aside the trust, and in the case of the Cayman Islands, the creditor/claimant must bring an action in the Cayman Islands courts (not in their home jurisdiction). The bar is set high for a potential claimant to successfully challenge a transfer. They must demonstrate an intention to defraud on behalf of the Settlor, and they must demonstrate they are an "eligible creditor" - meaning that at the date of the transfer, the transferor owes an obligation to the claimant. They must also be willing to bring an action in the Cayman Islands, which by itself is an expensive proposition. The burden of proof for a claimant to challenge a transfer into a Cayman Trust has a limitation period of six years. In Cayman it is possible to register a trust as an Exempt Trust however it is voluntary registration regime only, so most trusts remain unregistered. As most Cayman trusts are therefore private arrangements, it is hard to give exact figures for the popularity of AP Trusts governed by Cayman law. However the number of licensed trust companies give us some indication of how the jurisdiction is viewed. As of 30 September 2012 the Fiduciary Services Division of CIMA, the body responsible for licensing and regulating trust companies in the Cayman Islands has supervisory responsibility for 146 active trust licences. As the Cayman Islands are a British Overseas Dependent Territory, the quality of the judiciary is considered excellent, with the islands able to draw on the services of British lawyers and solicitors when contentious cases arise and expert lawyers with appropriate experience are required. The quality of banking and investment services are reasonably good. Cook Islands The Cook Islands claims to be the first country to have enacted an explicit asset protection law, implementing particular provisions in 1989 to its International Trusts Act. Several of these changes have been adopted in one form or another in several other countries and a handful of a U.S. states. The most important of these changes permits the settlor of a trust to be named as a spendthrift beneficiary. The trust laws of the Cook Islands provide a shortened statute of limitations on fraudulent transfer claims. While most U.S. states have a four-year statute of limitations (and the Statute