Fund Management Licensing and Registration

Who needs to apply

If your company wishes to conduct fund management activities regulated under the Securities and Futures Act 2001 (SFA) , it must apply to be either a:

  • Licensed fund management company (LFMC) that holds a capital markets services (CMS) licence; or
  • Registered fund management company (RFMC).

If your company solely manages venture capital funds, it may apply to be an LFMC that operates under the simplified venture capital fund manager (VCFM) regime.

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.

You can find out more about fund management activity and the differences between an LFMC, VCFM and RFMC here.

What are the admission criteria and applicable requirements?

When we assess your company to be an LFMC, VCFM or RFMC, MAS considers factors such as:

  • Credibility and substantiveness of the business model and plan, and the associated risks;
  • Effectiveness of risk management and compliance controls;
  • Fund management track record and expertise of an LFMC/RFMC applicant's management, parent company and major shareholders;
  • Fitness and propriety of the applicant, its shareholders and directors; and
  • Ability to meet the relevant minimum financial requirements prescribed under the SFA.

In addition, your company needs to operate from a dedicated and secure office space that is accessible only by your company’s directors and staff.

For more information on the admission criteria and applicable requirements, please refer to the Guidelines on Licensing, Registration and Conduct of Business for Fund Management Companies.

VCFMs are subject to a simplified set of admission criteria – please refer to Appendix 7 of the aforementioned guidelines

If your company is able to operate under an existing class exemption, it does not require a licence or registration. Examples of companies that may be eligible for exemption include those that:

  • Manage assets for related corporations or related family members;
  • Manage a pool of immovable assets for accredited and institutional investors; or
  • Manage a pool of non-capital markets product assets for accredited and institutional investors.

You can find more information on exemptions under section 99 of the SFA and paragraph 5 of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations .

How do I apply for licensing or registration?

If your company wishes to make an application, please submit the relevant form for your chosen fund manager type through the online Corporate e-Lodgment System (CeL). You may refer to the CeL user guide for more information. To read the forms, you will need Adobe Acrobat Reader version 9.4.4 or above.

 

Type of fund manager  LFMC  VCFM RFMC 
Applying for licensing or registration Form 1A 
(Application for a capital markets services (CMS) licence for fund management company)
Form 1V 
(Application for a CMS licence as a Venture Capital Fund Manager)
Form 22A 
(Notice of Commencement of Business as a Registered Fund Management Company)

In addition, if your company hires or appoints individuals to conduct regulated activity under your licence, you have to appoint these individuals as your representatives for that regulated activity.

Type of fund manager  LFMC VCFM  RFMC 
Appointing representatives Submit appointment forms for your representatives. Refer to the page Appointing a Representative for CMS Licensees or Exempt Financial Institutions for more information. Identify your representatives and their intended roles in the business plan section of Form 1V. A separate form is not required.  Indicate your representatives within Form 22A.

If your company also intends to deal in capital markets products (e.g. to operate a central dealing desk for equities, fixed income and derivatives) for its related companies that is separate from its fund management mandates, it will need to apply to add to its CMS licence the regulated activity of dealing in capital markets products as below.

Type of fund manager  LFMC VCFM RFMC
Applying to conduct additional regulated activity  

Please indicate the additional activity in section 1 of Form 1A if you are an LFMC applicant.

If you are an existing LFMC, submit Form 5 to your MAS officer-in-charge. There is a non-refundable application fee of S$500 payable via GIRO.

 

You will also have to appoint individuals who conduct the additional dealing activity as your representatives. Your company and the dealing representatives will have to comply with relevant capital and conduct requirements applicable to this activity under the SFA .

Generally, you do not have to add dealing activity to your CMS licence if the activity is incidental to your fund management activity.
 

Not applicable Not applicable 

How much is the application fee and how do I make payment?

For LFMC and VCFM, there is a non-refundable application fee of S$1,000. Upon submission of the application via CeL, you will receive instructions on the amount of application fees payable on the acknowledgement page. For the lodgment fees for representatives that your company appoints, please refer to Appointing a Representative for CMS Licensees or Exempt Financial Institutions.

What is the processing time required?

We expect to take up to 6 months to review applications which are complete and by applicants that meet all admission criteria.

Applications may take longer if the applicant does not fully meet relevant admission criteria, has unique and complex business models, or does not submit all necessary forms, information and documents in the initial application. A longer review period should be expected if significant changes are made to the initial application. MAS may require a fresh submission in such situations.

An in-principle approval (IPA) is issued to successful applicants at the conclusion of our review process, and the applicant has up to 6 months to fulfil specified requirements for licensing or registration. As soon as the applicant meets these requirements, MAS will grant the licence or registration. MAS reserves the right to rescind the IPA if the applicant does not fulfil the requirements within the timeline, or if there are changes to the applicant’s business plan and/or key persons after IPA has been issued. At its discretion, MAS may extend the IPA by a further 3 months if there are strong reasons to do so.

What is the annual fee to be paid by a fund manager?


Type of fund manager  LFMC VCFM   RFMC
 Annual corporate fee
  • Fixed fee of S$4,000
  • Variable fee calculated at S$5 per representative from the 101st representative onwards as at 1 January of the calendar year 

S$4,000

S$1,000


In addition to the annual corporate fee for the licence or registration status, there will also be annual fees for representatives appointed by an LFMC. Details can be found in Appointing a Representative for CMS Licensees or Exempt Financial Institutions.

What is the validity of the licence and registration?

The licence or registration is valid until:

All entities that are registered or holding a CMS licence to conduct regulated fund management activities are listed on the Financial Institutions Directory. Fund managers that cease to be registered or licensed will be removed from the directory.

For more information

MAS also publishes a Licensing and Registration Report for Capital Markets Intermediaries (including fund management companies).

For more information on the common approvals, notifications and other regulatory submissions relevant to fund management companies, please refer to the Compliance Toolkit for Approvals, Notifications and Other Regulatory Submissions to MAS for Fund Managers.