Singapore is a hub for global and local asset managers in the Asia-Pacific region, making it a preferred and trusted domicile for funds. Our previous article, published in December 2020, covered the Variable Capital Companies (VCCs), a flexible corporate structure introduced fairly recently in Singapore, designed for investment funds.
This article covers key legal and compliance requirements as well as general guidelines applicable to the setting up of fund management companies. We discuss:
To conduct regulated fund management activities under the SFA, a company must be registered with the Monetary Authority of Singapore (MAS) or hold a Capital Markets Services (CMS) licence to operate either as a Registered Fund Management Company (RFMC), a Licensed Fund Management Company (LFMC), or a Venture Capital Fund Manager (VCFM). The relevant requirements for the setting up of each type of fund management company are set out in the table below.
Further, note that individuals performing key functions in a fund management company, such as portfolio construction and allocation, research and advisory, business development and marketing or client servicing are required to be “representatives”. To meet the requirements of being a “representative”, such individual needs to:
We set out below the general guidelines, eligibility criteria and application procedures for Licensed Fund Management Companies (LFMCs), Venture Capital Fund Managers (VCFMs), and Registered Fund Management Companies (RFMCs).
Fund management companies (namely LFMCs, VCFMs and RFMCs) should also meet ongoing business conduct requirements, such as requirements relating to custody, valuation and reporting, conflicts of interest mitigation, disclosure and submission of periodic returns. These are set out in the MAS Guidelines on Licensing, Registration and Conduct of Business for Fund Management Companies.
When assessing an application to be an RFMC, LFMC or VCFM, the MAS takes into account factors such as:
The following materials are available on the MAS website:
This update is provided to you for general information and should not be relied upon as legal advice.
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