The Second Schedule to the Securities and Futures Act (SFA) defines the activity of fund management. A corporation that carries on business in fund management in Singapore would need to either hold a CMS license in fund management or be registered with the Monetary Authority of Singapore (MAS) as an RFMC.

The Second Schedule to the Securities and Futures Act (SFA) defines the activity of fund management. A corporation that carries on business in fund management in Singapore would need to either hold a CMS license in fund management or be registered with the Monetary Authority of Singapore (MAS) as an RFMC.

Retail Licensed Fund Management Companies (LFMC’s) are carrying on business in fund management with all types of investors (without restriction on the number of investors).

Venture Capital Fund Managers (VCFM’s) are carrying on business in fund management in respect of venture capital funds with qualified investors only (without restriction on the number of qualified investors). Venture capital funds are subject to restrictions on investments and fund type.

The Registered Fund Management Company (RFMC) is carrying on business in fund management with no more than 30 qualified investors (of which no more than 15 may be funds or limited partnership fund structures) and the total value of the assets managed does not exceed S$250 million.

The Registered Fund Management Company (RFMC) is carrying on business in fund management with no more than 30 qualified investors (of which no more than 15 may be funds or limited partnership fund structures) and the total value of the assets managed does not exceed S$250 million.

A Registered Fund Management Company (RFMC) should periodically monitor the size of the assets being managed for the purpose of ensuring that it is adhering to the limit of S$250 million.

The Monetary Authority of Singapore (MAS) should be satisfied by the Fund Management Company (FMC) that its shareholders, directors, representatives and employees as well as the FMC itself are fit and proper in accordance with the guidelines on Fit and Proper Criteria issued by the MAS.

The Chief Executive Officer, directors and relevant professionals of the Fund Management Company (FMC) must have adequate experience that is relevant to the fund management activities of the FMC. The board of directors of the FMC should collectively have experience in portfolio management as well as in support functions such as risk management, operations and compliance. At least one of the Executive Directors should have portfolio management experience in asset classes or markets that the FMC intends to invest.

A Fund Management Company (FMC) shall at all times maintains the base capital requirement of S$1,000,000 for carrying out fund management in respect of any CIS offered to any investor other than an accredited or institutional investor.

A Fund Management Company (FMC) shall at all times maintain the base capital requirement of S$500,000 for carrying out fund management (non-CIS) on behalf of any customer other than an accredited or institutional investor.

Risk-based capital requirement of “financial resources at least 120% of operational risk requirement” should meet by a Retail Licensed Fund Management Company (LFMC) at all times upon obtaining its license.

The Monetary Authority of Singapore (MAS) expects that a Fund Management Company (FMC) should have in place compliance arrangements that are commensurate with the nature, scale and complexity of its business. The ultimate responsibility for compliance with applicable laws and regulations rests with the FMC’s CEO and board of directors, even though compliance support may be provided by a foreign-related entity and/or third-party service providers. Where an FMC has an in-house compliance officer, the individual is expected to have relevant experience for example, in regulatory compliance, audit or risk management and be familiar with the rules and regulations applicable to the FMC.

The Monetary Authority of Singapore (MAS) expects that a Fund Management Company (FMC) should have in place compliance arrangements that are commensurate with the nature, scale and complexity of its business. The ultimate responsibility for compliance with applicable laws and regulations rests with the FMC’s CEO and board of directors, even though compliance support may be provided by a foreign-related entity and/or third-party service providers. Where an FMC has an in-house compliance officer, the individual is expected to have relevant experience for example, in regulatory compliance, audit or risk management and be familiar with the rules and regulations applicable to the FMC.

The Monetary Authority of Singapore (MAS) expects that a Fund Management Company (FMC) should have in place compliance arrangements that are commensurate with the nature, scale and complexity of its business. The ultimate responsibility for compliance with applicable laws and regulations rests with the FMC’s CEO and board of directors, even though compliance support may be provided by a foreign-related entity and/or third-party service providers. Where an FMC has an in-house compliance officer, the individual is expected to have relevant experience for example, in regulatory compliance, audit or risk management and be familiar with the rules and regulations applicable to the FMC.

The Monetary Authority of Singapore (MAS) expects that a Fund Management Company (FMC) should have in place compliance arrangements that are commensurate with the nature, scale and complexity of its business. The ultimate responsibility for compliance with applicable laws and regulations rests with the FMC’s CEO and board of directors, even though compliance support may be provided by a foreign-related entity and/or third-party service providers. Where an FMC has an in-house compliance officer, the individual is expected to have relevant experience for example, in regulatory compliance, audit or risk management and be familiar with the rules and regulations applicable to the FMC.

Monetary Authority of Singapore (MAS) expects the business activities of a Fund Management Company (FMC) to be subject to adequate internal audit. The internal audit arrangements should be commensurate with the scale, nature and complexity of its operations. The internal audit may be conducted by the internal audit function within the FMC, an internal audit team from the head office of the FMC or outsourced to a third-party service provider.

A Fund Management Company (FMC) shall meet the annual audit requirements as set out in the Securities and Futures Act (SFA) and SF(LCB)R. Monetary Authority of Singapore (MAS) may direct the FMC to appoint another auditor if the appointed auditor is deemed to be unsuitable, having regard to the scale, nature and complexity of the FMC’s business.

The Monetary Authority of Singapore (MAS) may require licensed fund management companies (LFMCs) to procure a letter of responsibility from the LFMC’s parent company.

The following factors should be considered by the Monetary Authority of Singapore (MAS) while assessing an application for a Capital Markets Services (CMS) License in fund management:-

(a) A Retail LFMC should demonstrate that it or its shareholders have at least a 5-year track record of managing funds for retail investors in a jurisdiction that has a regulatory framework that is comparable to Singapore.
(b) The Fund Management Company (FMC) and its related corporations should manage total assets of at least S$1 billion.
(c) Track record of the licensed fund management company (LFMC) or its holding company or a related corporation.

A Fund Management Company (FMC) should ensure that there is adequate disclosure to its customers in respect of each fund or account that it manages. Disclosures should, at the minimum, cover the following:-

(a) The investment policy and strategy, as well as risks associated with the strategy.
(b) The terms with respect to fees, termination or exit and, where applicable, gating, side-pocketing, lock-up or suspension of redemptions, including any penalties that may apply under such circumstances.
(c) The circumstances under which the fund or account can be terminated, as well as the processes for effecting such termination.
(d) The counterparties, brokers and prime brokers used by the fund or account.
(e) The valuation policy and performance measurement standards. Where there are investments in hard-to-value or illiquid assets, the methodology and procedures for their valuation should be disclosed.
(f) The use of leverage, to the extent permitted by the investment mandate. The definition and measurement of leverage, as well as the circumstances under which leverage may be used, should be disclosed.
(g) The custodians, trustees, fund administrators and/or auditors used by the fund or account.

The Fund Management Company (FMC) should ensure that the decision to terminate a fund and the process of termination is in the interest of investors in the fund and all investors are treated fairly and equitably. The following points should be maintained by the FMC:-

(a) The FMC should maintain appropriate governance and oversight of the termination process.
(b) The FMC should establish written policies for handling the termination process, covering areas such as the allocation of the costs of termination, investor communications, and treatment of unclaimed proceeds (where relevant).
(c) The FMC should provide timely information to all investors so that they are kept updated on the progress of the termination.

Corporate Electronic Lodgment (CeL) is used for submission of an application by a prospective Fund Management Company (FMC) to registering with the Monetary Authority of Singapore (MAS) as a Registered Fund Management Company (RFMC).

Corporate Electronic Lodgment (CeL) is used for submission of an application by a prospective Fund Management Company (FMC) to applying a for Capital Markets Services (CMS) License in fund management.

Corporate Electronic Lodgment (CeL) is used for submission of an application by a prospective Fund Management Company (FMC) to applying for Capital Markets Services (CMS) License in fund management, in respect of venture capital funds only.

Persons who are interested in applying for a fund management license or in operating as a registered fund management company (RFMC) may contact the Monetary Authority of Singapore (MAS) on the following addresses:-

(a) By Post: Capital Markets Intermediaries Department II, 10 Shenton Way MAS Building, Singapore 079117.
(b) By Email: [email protected].
(c) By Phone: (65) 6225 5577.

A Registered Fund Management Company (RFMC) or Licensed Fund Management Company (LFMC) is required to appoint an adequate number of directors, relevant professionals and representatives. The RFMC or LFMC should appoint a Chief Executive Officer (CEO). There is no restriction on the CEO to take on multiple appointments within the firm if there are synergies, e.g. the CEO can also be appointed as Executive Director, relevant professional and representative. The individual would then need to meet the requirements in respect of each appointment.

A Registered Fund Management Company (RFMC) or Licensed Fund Management Company (LFMC) is required to appoint an adequate number of directors, relevant professionals and representatives. The RFMC or LFMC should appoint a Chief Executive Officer (CEO). There is no restriction on the CEO to take on multiple appointments within the firm if there are synergies, e.g. the CEO can also be appointed as Executive Director, relevant professional and representative. The individual would then need to meet the requirements in respect of each appointment.

Minimum years of relevant experience required for the appointment of a Chief Executive Officer (CEO) of the Registered Fund Management Company (RFMC) or A/I Licensed Fund Management Company (A/I LFMC) is 5 years. A CEO should have managerial experience or experience in a supervisory capacity as part of the individual’s relevant experience.

Minimum years of relevant experience required for the appointment of a Chief Executive Officer (CEO) of a Retail Licensed Fund Management Company (Retail LFMC) is 10 years. A CEO should have managerial experience or experience in a supervisory capacity as part of the individual’s relevant experience.