How do you determine if a fund is a major fund?

The list of fund management companies are listed in the Financial Institutions Directory.

Who needs to apply?

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:

  • Registered fund management company (RFMC) or
  • Licensed fund management company (LFMC). Managers of venture capital funds may also apply to operate under the 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 various types of fund management authorisation statuses here.

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

What are the admission criteria and applicable requirements?

When assessing an application to be an RFMC, LFMC or VCFM, MAS takes into account factors such as:

  • Fitness and propriety of the applicant, its shareholders and directors.
  • Track record and fund management expertise of the applicant and its parent company or major shareholders.
  • Ability to meet the minimum financial requirements prescribed under the SFA.
  • Strength of internal risk management and compliance systems.
  • Business model/ plans and projections and the associated risks.

In addition, your company would need 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.

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.

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

What are the applicable financial and staffing requirements?

Type of fund managerRetail LFMCAccredited/Institutional LFMC (A/I LFMC)VCFMRFMC
Financial requirements

More details on the base capital and other financial requirements can be found in the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations (SF(FMR)R) . The base capital requirements are set out in the First Schedule to the SF(FMR)R .

Details of the financial resources requirement are found in the Notice SFA 04-N13 Risk Based Capital Adequacy Requirements for Holders of Capital Markets Services Licences.

  • Minimum base capital of S$500,000 or higher
  • Required to maintain financial resources which are in excess of its total risk requirements
  • Minimum base capital of S$250,000
  • Required to maintain financial resources which are in excess of its total risk requirements
  • Minimum base capital of S$0
  • Minimum base capital of S$250,000
Staffing requirements 
  • Minimum of 3 full-time Singapore-based employees each with at least 5 years of relevant experience
  • Proposed CEO must have at least 10 years of relevant experience
  • Independent and dedicated compliance function in Singapore required
  • Minimum of 2 full-time Singapore-based employees each with at least 5 years of relevant experience
  • Independent and dedicated compliance function in Singapore required if AUM is at least S$1 billion
  • Minimum of 2 full-time Singapore-based employees
  • Minimum of 2 full-time Singapore-based employees each with at least 5 years of relevant experience

Annual corporate fee

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.

  • 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

How do I apply for licensing or registration?

Type of fund managerRetail LFMC or A/I LFMCVCFMRFMC

Applying for licensing or registration

If your company is making an application, submit the relevant form for that type of fund manager online through the Corporate e-Lodgment System (CeL). For information on CeL, please refer to the CeL user guide. To access the forms, you will need Adobe Acrobat Reader version 9.4.4 or above.

Form 1A (Application for a capital markets services (CMS) licence to provide fund management)

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. 

Form 1V (Application for a CMS licence as a Venture Capital Fund Manager)

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.

Form 22A (Notice of Commencement of Business as a Registered Fund Management Company)

Appointing representatives

If you hire or appoint individuals to conduct a regulated activity under your licence, you have to appoint these individuals as your representatives for that regulated activity.

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. A separate form is not required. Indicate your representatives within the Form 22A.

Applying to conduct additional regulated activity

If your company also intends to deal in capital markets products (e.g. equities, fixed income and derivatives) for your related companies, you will need to apply to add this activity.

If you are applying to be an LFMC, select the applicable option(s) in section 1 of Form 1A.

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 .

Not applicable Not applicable

What is the processing time required?

Due to the higher volume of applications to MAS presently, we expect to take up to 6 months to review LFMC and RFMC applications, and up to 4 months to review VCFM applications. An in-principle approval is issued to successful applicants at the conclusion of our review process. Applicants have up to 6 months to fulfil requirements set out in the in-principle approval. These requirements typically relate to provision of undertakings, topping up of share capital or formalising the appointments of certain key personnel. The timeline for this phase depends on how speedily the applicant can fulfil the requirements.

Applications may experience a longer review period, 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. The applicant should also expect a longer review period if it makes significant changes after making its initial application. MAS may require a fresh submission in such situations.

What is the validity of the licence or registration?

The licence or registration is valid until:

  • The fund manager stops conducting all the regulated activities on the CMS licence, and the licence is cancelled by MAS, or cease to conduct business as an RFMC.
  • The licence or registration is revoked by MAS.
  • The licence lapses in accordance with section 95 of the SFA , or the registration ceases in accordance with paragraph 5(2)(bb) of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations .

All entities that are registered or holding a CMS licence to conduct regulated fund management activities are listed on the Financial Institutions Directory. Correspondingly, all fund managers that ceased to be registered or hold a licence will be removed from the Financial Institutions Directory.

How do you tell if a fund is a major fund?

A major fund is defined as those funds whose revenues, expenditures/expenses, assets or liabilities are at least 10 percent of the total for their fund category (governmental or enterprise) and 5 percent of the aggregate of all governmental and enterprise funds in total.

Which is always a major fund?

(The general fund is always considered a major fund, regardless of its individual balances.)

What are the three major categories of funds?

CLASSIFYING FUNDS-GAAP BASIS - 7420. The generally accepted accounting principles (GAAP) basis classification divides funds into three broad fund categories: Governmental, Proprietary, and Fiduciary.

What does Major funding mean?

MAJOR FUND means a governmental or enterprise fund reported as a separate column in the basic fund financial statements.