A company needs to be licensed for fund management if it raises and manages monies for third-party investors in collective investment schemes, or segregated accounts, that invest into capital markets products, such as equities, fixed income assets and financial derivatives. 

Depending on the size of the company’s expected assets under management, target clientele and investment strategy, it can operate as: 

• 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 Guidelines on Licensing and Conduct of Business for Fund Management Companies 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 licensing, please refer to the Fund management licensing 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 representatives. To find out how to appoint individuals as a fund manager’s representatives, please refer to the Appointing a Representative for CMS Licensees or Exempt Financial Institutions page.

Depending on the types of investors and investment assets, a company may be eligible for an exemption from licensing 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 products 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 .

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:

• Guidelines on Licensing and Conduct of Business for Fund Management Companies; and 
  
• Compliance Toolkit for Approvals, Notifications and Other Regulatory Submissions to MAS for Fund Managers.
  
  

[1] See licensed fund management company , venture capital fund manager .