MAS Consultation Paper on Repeal of Regulatory Regime for Registered Fund Management Companies

  • Ingenia Consultants
  • October 30, 2023

The Monetary Authority of Singapore (MAS) published a consultation paper on the repeal of the regulatory regime for registered fund management companies (“RFMCs”) on 24 October 2023. Importantly, this consultation paper does not consult if the regulatory regime for RFMCs should be repealed but only consults on the terms of this repeal. Hence, we may conclude that the regulatory regime for RFMCs will be repealed.

In the consultation paper, the MAS has not indicated a date when the regulatory regime for RFMCs will be repealed. However, the MAS will stop accepting applications for new RFMCs on 31 December 2023. We may, therefore, assume that the regulatory regime for RFMCs will be repealed in 2024.

Existing RFMCs will need to apply for and be granted a capital markets services (“CMS”) licence for fund management prior to the repeal of the regulatory regime for RFMCs. The MAS is preparing a special application form for this purpose. No application fee will be charged. Existing RFMCs will need to submit their application to the MAS at least one month before the repeal of the regulatory regime for RFMCs. The MAS is expected to respond to the application within one month of submission. Successful applicants will be issued a CMS licence upon the repeal of the RFMC regime.

RFMCs are expected to convert to licensed fund management companies restricted to servicing qualified investors, namely accredited investors and institutional investors (“A/I LFMC”), the same customer restriction as an RFMC. Despite the upgrading of the licence, the MAS intends to maintain the cap of SGD 250 million in assets under management (“AuM”) for converted RFMCs. Converted RFMCs will later need to apply for the lifting of this restriction on AuM once they come close to exceeding the limit. In contrast, the restriction for RFMCs on the number of customers will not apply anymore.

Please note that the above information is based on a consultation paper that is open for responses until 31 December 2023. The terms of the conversion of RFMCs to A/I LFMCs may, therefore, still be subject to change.

For any further information, please contact:
Rolf Haudenschild
Co-founder
Ingenia Consultants Pte. Ltd.
rolf.haudensschild@ingenia-consultants.com