Depending on the size of the company’s expected assets under management, target clientele and investment strategy, it can operate as a:
- Registered Fund Management Company (RFMC), which can have up to 30 accredited and institutional investors, and S$250 million of assets under management (AUM), or
- Capital markets services (CMS) licence holder for fund management (licensed fund management company, or LFMC). An LFMC has no restriction on the number of investors or AUM, and can be further categorised into:
- Retail LFMC – Carries on business in fund management with all types of investors, including retail investors.
- Accredited/Institutional LFMC (A/I LFMC) – Carries on business in fund management with accredited and institutional investors only.
- Venture Capital Fund Manager (VCFM) – Manages venture capital funds only. These funds have to meet certain fund eligibility criteria such as being mainly invested in start-ups (see for details of the specific criteria). VCFMs are restricted to serving only accredited and institutional investors.
For additional information on key differences in requirements for the various categories of fund managers and how you can submit an application for registration or licensing, please refer to the page.
Individuals performing regulated activity in a fund manager, such as portfolio construction and allocation, research and advisory, business development and marketing or client servicing are required to be . To find out how to appoint individuals as a fund manager’s representatives, please refer to the page.
Depending on the types of investor and investment assets, a company may be eligible for an exemption from licensing or registration to conduct fund management. Examples of such companies are 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.
A fund manager is required to put in place business conduct policies, procedures and controls which are commensurate with the nature, scale and complexity of its business. The fund manager is also subject to conduct requirements such as segregation of customers’ moneys and assets, independent valuation of its assets under management, and mitigation of conflicts of interest. All fund managers must comply with MAS’ requirements on anti-money laundering and countering terrorism financing.
For more information on applicable requirements, please refer to: