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Singapore is known for being a regional hub for wealth management. The government issues various fund management licences for different needs of fund managers and established regulations around them. We help you with the technical jargons, walk you through the regulatory requirements and assist in the application of Capital Markets Services (CMS) licences issued by the Monetary Authority of Singapore (MAS).
Companies that conduct any of the following regulated activities are required to hold a CMS licence:
There are a lot of rules, guidelines, and processes involved in obtaining fund management licenses in Singapore.
Our team of professionals formerly from the Big 4, banks and regulator simplify the journey for you. We’ll follow all of the steps necessary to get you registered, from beginning to end. We offer guidance on the various licensing requirements for any categories that financial institutions ask for. Whether you’re a fund manager, financial adviser, insurance broker, trust manager company, or payment services provider, we can help.
Our experienced team shall hand-hold and guide you along the licensing journey.
Outsource filing MAS license applications & leave the stress to us. We have extensive experience in the application of fund management licenses for hedge fund managers, private equity fund managers, venture capital fund managers, external asset managers, multi-family offices and single-family offices,. The types of licenses include:
We will be with you during the entire journey from drafting, submission, and attending to MAS queries to finally obtaining the licencse. Outsource the preparation and submission of MAS license applications to us as we have the best team to guide and help you navigate through the regulator’s requirements.
We have successfully applied for various types of licences issued by the MAS. Our high success rate is primarily attributable to our tailored and comprehensive approach in assessing the key factors, through the regulator’s lenses:
It typically takes between 4 to 6 months for MAS to assess an application.
Successful applicants will be granted in-principle approval. The applicants must fulfil all the pre-requisites within the stipulated timeline as stated in the in-principle approval letter.
If applicants do not meet the licensing criteria, have complex business models, or fail to provide necessary forms, information or documents at time of initial application, they may experience a longer review period.
Outsource filing MAS license applications to us and we will strive to make it a worry-free experience for you.
MAS issued a consultation paper on the Repeal of Regulatory Regime for Registered Fund Management Companies (“RFMCs”) on 24 October 2023. The closing date of the consultation paper is on 31 December 2023. The consultation paper seeks feedback on the proposed transitional arrangements for existing RFMCs that intend to continue operating fund management businesses following the repeal of the regulatory regime for RFMCs. The repeal of the RFMC regime would have an impact on your proposed business plan of applying for a RFMC licence.
To minimise the number of RFMC applications by the time of the repeal, MAS will stop accepting new RFMC applications from 1 January 2024. From 1 January 2024 onwards, applicants seeking to conduct fund management can apply for a CMS licence for fund management, after ensuring that they are able to meet all admission and ongoing requirements. MAS will continue to review any RFMC application that remains outstanding after 1 January 2024, with a view to registering all successful applicants before the repeal date.
Please contact us for the latest information and complimentary advice on what to prepare for such transition.
Under the SFA, a person who wishes to carry on a business in any regulated activity is required to hold a capital markets services [“CMS”] licence for that regulated activity. A CMS licence is granted only to a corporation. An individual who conducts that regulated activity for the holder of a CMS licence is required to be an appointed, provisional or temporary representative of the CMS licence holder for that regulated.
If your company wishes to conduct regulated fund management activities under the Securities and Futures Act (SFA), it must be registered with MAS or hold a capital markets services (CMS) licence to operate either as a:
The operation of discretionary accounts on behalf of customers for the purpose of trading or investment in capital markets products is considered to be fund management as it allows the persons who operate such accounts to trade and manage the investments in the account on behalf of customers. Under the SFA, fund management is defined to mean managing the property of, or operating, a collective investment scheme, or undertaking on behalf of customers (a) the management of a portfolio of capital markets products; or (b) the entry into spot foreign exchange contracts for the purpose of managing customer’s funds.
Hence, a company that holds a CMS licence for dealing in capital markets products, and wishes to operate discretionary accounts on behalf of its customers, would need to apply to MAS to add the activity of fund management to its licence
The term ‘single family office’ is not defined under the SFA. An SFO typically refers to an entity which manages assets for or on behalf of only one family and is wholly owned or controlled by members of the same family. The term ‘family’ in this context may refer to individuals who are lineal descendants from a single ancestor, as well as the spouses, ex-spouses, adopted children and stepchildren of these individuals.
It is not MAS’ intention to license or regulate SFOs. There are existing class exemptions from licensing under the SFA and FAA for the provision of fund management and financial advisory services respectively to related corporations
A fund manager may operate under the VC Manager Regime if and only if all of the funds that it manages meet the following eligibility criteria:
(a) invest at least 80% of committed capital (excluding fees and expenses) in securities that are directly issued by an unlisted business venture that has been incorporated for no more than ten years at the time of initial investment (“qualifying investments”). Any follow-on investment in such qualifying investments will remain as qualifying, even if the portfolio company has been incorporated for more than ten years at the point of follow-on investment; and
(b) be allowed to invest up to 20% of committed capital (excluding fees and expenses) in other unlisted business ventures that do not meet subcriterion (a), i.e. they have been incorporated for more than ten years at the time of the initial investment, and/or the investment is made through acquisitions from other investors (e.g. other VC funds and existing owners) in the secondary market (“non-qualifying investments”).the funds must not be continuously available for subscription, and must not be redeemable at the discretion of the investor; and
(c) the funds are offered only to accredited investors as defined under the SFA or investors in an equivalent class under the laws of the country where the offer is made, and/or institutional investors.
For clarity, a VCFM’s funds can only make investments (nonqualifying or otherwise) in unlisted assets. The funds cannot invest in listed securities or initial public offerings. However, this does not preclude a VCFM’s funds from holding listed securities in portfolio companies, provided that the fund had acquired these securities prior to their listing. VCFMs are not expected to reclassify an investment from qualifying to non-qualifying if its portfolio company’s securities become listed.