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Setting up a fund management company in Singapore (Applications) – Key areas of considerations

Fund management activities in Singapore are regulated by the Monetary Authority of Singapore (“MAS”) under the Securities and Futures Act (Cap. 289) (“SFA”). Entities engaging in such activities must hold one of the following licences or registration below.

In consideration of the licences or registration above, please find some of the key areas that needs to be considered when preparing an application. (Note that these are not exhaustive and there are other considerations involved as part of the licensing or registration process.)

1. Substantive Fund Management Activity

The applicant must demonstrate to MAS that substantive fund management activities are conducted in Singapore such as:

  • acting as an investment adviser, sub-adviser or provides research to other investment managers (either in Singapore or overseas)

  • able to exercise influence or control over the management of the investment portfolio or provide inputs to the portfolio composition

The applicant would not qualify for a fund management licence or registration if:

  • the entity is merely a conduit or channel for its customer to structure its investments or assets without providing any substantive input or influence over the investment

  • the entity is set up as a fund structure solely to raise capital for an operating business that is run or managed by the person, or purely engages in marketing of funds and/or client

2. Key personnel requirements and competency of key individuals

The CEO, directors and relevant professionals of the fund management company must have adequate experience that is relevant to the fund management activities of the fund management company.

MAS will not consider experience in investing one’s own moneys as relevant experience in the context of a fund management company that is seeking to be regulated to manage monies for third parties.

The CEO and directors of a fund management company must collectively have the competencies and authority that would allow them to exercise effective control over the activities of the fund management company and its employees (i.e., to be sufficiently anchored to the fund management company, by holding substantial shareholding stakes in the company), so as to align the interests of the owners and the management team of the fund management company.

3. Requirement to meet the Fit and Proper criteria

The applicant must ensure that its shareholders, related entities, directors, representatives and employees, as well as the fund management company itself meet the Fit and Proper criteria stipulated by MAS’ Guidelines on Fit and Proper Criteria (“FSG-G01”).

Established since 2013, Lymon has been providing regulatory compliance and risk management services to financial institutions in Singapore, including assisting our clients with their MAS licence applications.

To find out more about how we can help you obtain a Singapore fund management licence, do reach out to your usual contact at Lymon or our specialist below:

internal audit, compliance consulting, regulatory compliance, internal audit outsourcing, internal audit services

Jovi Gan, Director

+65 6709 4110


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