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Singapore regulatory update 2024

19 April 2024

The Monetary Authority of Singapore (“MAS”) has issued a response to feedback on the Repeal of Regulatory Regime for Registered Fund Management Companies (“RFMCs”). The repeal aims to streamline regulations for all Singapore fund managers.

The repeal will take effect on August 1 2024. To continue with fund management activity after this date, existing RFMCs must apply for a Capital Markets Services (“CMS”) License as an A/I Licensed Fund Management Company (“LFMC”) by completing Form 1AR.

No supporting documents are required at the point of submitting Form 1AR. However, applicants must be prepared to provide documentation in support of the declarations made in the application if requested by MAS.

MAS will approve an application to be an A/I LFMC if the RFMC:

  • has managed assets attributable to third-party investors in the six months immediately preceding the submission of the form to MAS. This requirement does not apply if the RFMC is registered for six months or less as at the submission date;
  • submits Form 1AR on time;
  • satisfactorily furnishes supporting document upon request by MAS.

The transition period for this application is from April 1 to June 30 2024

MAS will inform RFMCs of the outcome of their application within a month of submission and expects to issue capital markets services (“CMS”) licences to all successful applicants by end July 2024. A/I LFMCs are required to comply with the regulatory requirements as a Fund Management Company.

RFMCs that do not obtain CMS licences before the repeal date will no longer have a valid regulatory status to carry out fund management when the repeal takes effect. Unless an existing licensing exemption applies, they will be in breach of regulatory requirements if they continue to carry out any regulated activity under the SFA.

FMCs intending to cease their fund management business should ensure an orderly winding down of their operations. This applies to RFMCs that do not apply for or obtain CMS licenses when the repeal takes effect.

How can we help?

If you need assistance with the submission of the application form and ongoing compliance framework to ensure compliance with the relevant regulatory framework and reporting requirements in Singapore, we're here to help.

  • MAS licensing applications
  • MAS policies and procedures
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  • AML/CFT training

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