On 26 June 2025, the Monetary Authority of Singapore (MAS) issued circular no. IID 04/2025 (Circular) to all regulated fund managers that manage a VCC (VCC Managers). After undertaking a survey of the VCC Managers and analysing information from their statutory lodgements, MAS sought, through the Circular, to share “supervisory expectations and good practices” for VCC Managers. Whilst it does not have force of law, the Circular will no doubt be closely studied by compliance professionals and regulatory advisors as, apart from the Variable Capital Companies Act 2018 and the regulations made thereunder, there has hitherto been little in guidance from MAS on its regulatory expectations as to the governance and management of VCCs.
In this update, our Head of Asset Management & Funds, Low Kah Keong, together with Asset Management & Funds Partner, Felicia Marie Ng, take a closer look at and share some key insights arising from MAS’ supervisory expectations of VCC directors as set out in the Circular.
If you would like information and/or assistance on the above or any other area of law, you may wish to contact the Partner at WongPartnership whom you normally work with or any of the following Partners:
LOW Kah Keong
Head – Asset Management & Funds
d +65 6416 8209
e kahkeong.low@wongpartnership.com
Click here to view Kah Keong’s CV.
Felicia Marie NG
Partner – Asset Management & Funds
d +65 6416 8203
e felicia.ng@wongpartnership.com
Click here to view Felicia’s CV.