Repeal of Regulatory Regime for Registered Fund Management Companies

26 Oct 2023 Legal Highlights

The Monetary Authority of Singapore ("MAS") has just published a consultation paper on its proposal to repeal the registered fund management company ("RFMC") regime. RFMCs are a class of fund management companies which are subject to reporting requirements that are relatively less onerous as compared to licensed fund managers – the key difference between RFMCs and licensed fund managers which are restricted to serving accredited/institutional investors is that RFMCs are additionally subject to limits on the number of clients they may have and the value of assets which they may manage. MAS is proposing to repeal the RFMC regime to simplify the regulatory regime and harmonise the applicable requirements for fund managers.


For existing RFMCs, MAS' proposals would require them to file a prescribed application form within a stipulated timeline, with successful applicants being granted a capital markets services licence for fund management. The current AUM limit of S$250 million will be retained via a licence condition to be imposed on such transitioned RFMCs, which may subsequently engage with MAS to review and lift this restriction. Transitioned RFMCs would then be subject to all the same regulatory requirements as currently applicable to licensed fund managers. MAS will also stop accepting RFMC applications from 1 January 2024 to minimise the number of "transitional" applications to be reviewed when the proposals are implemented.


The Consultation Paper can be accessed here.


Our Financial Services Regulatory Practice has advised on a broad range of issues that concern Financial Institutions, including licensing related matters for fund management companies. Reach out to our Financial Services Regulatory Practice Partners Elaine Chan, Rosabel Ng, Chan Jia Hui, Tian Sion Yoong, if you have any questions on the proposals or require assistance with the RFMC transition process. You may also find out more about our practice here.