RFMCs Permissible Activities
Carrying on business in fund management with no more than 30 qualified investors (of which no more than 15 may be funds or limited partnership fund structures) and the total value of the assets managed does not exceed S$250 million.
When assessing an application to be an RFMC, 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, the company would need to operate from a dedicated and secure office space that is accessible only by the company’s directors and staff.
Minimum base capital of S$250,000
Minimum of 2 full-time Singapore-based employees each with at least 5 years of relevant experience
If individuals are hired or appointed to perform key functions, such as portfolio construction and allocation, research and advisory, business development and marketing or client servicing, these individuals have to be appointed as the representatives.
Documents Required for Registration as an RFMC
Signed declaration by RFMC’s directors (from Form 22A);
RFMC’s business profile as per the Accounting and Corporate Regulatory Authority’s record;
RFMC’s complete group shareholding chart;
Information on the company's proposed business plan; and
Provide a brief description of the company's proposed business model and outline of the activities to be carried out in Singapore.
RFMC’s organisational chart with reporting lines of the Company.
The chart should clearly show the reporting lines of all employees to the CEO and the directors, including functional reportings to staff who are located outside Singapore. The chart should also include job functions and designations of all employees, including those in compliance, risk management and internal audit functions.
Processing Time Required
MAS expects to take not more than 4 months to review and process an application if the business model is straightforward, the applicant meets the relevant admission criteria fully, and the application is complete and clear. For more complex cases, or cases where information is assessed to be incomplete or inaccurate, MAS will need a longer time to review the application.
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Bestar assists in preparation and submission of the following for MAS registration:
A clear description of the applicant’s business model and plans, which are supported by the professional experience and expertise of the proposed management team. The business plan sets out the investment focus or strategy to be adopted, assets and markets where investments will be made, the profile of potential investors and distribution plans or channels;
A clear description of risk management, compliance and audit arrangements which are in line with the nature of the proposed fund model;
For applicants which are part of a global fund management group, a clear explanation of the applicant’s role in Singapore together with the functions or services that it will receive and/or provide to related corporations within the group (if any);
Documentary evidence of the applicant’s ability to meet minimum base capital and financial requirements, including the ACRA business profile report and where available, the latest audited financial statements;
Where regulatory action has previously been taken against the applicant or its related corporations, an assessment of the impact of the action and a description of the steps taken to effectively address the root cause of the regulatory breach; and
Fit and proper declarations by the applicant for its shareholders, directors and representatives. In relation to shareholders, declarations are provided for: (i) shareholders with 5% or more direct or indirect voting power or ownership in the applicant, and (ii) where a shareholder is publicly listed company, persons who own or control 5% or more of the shares of the company.
If you would like to know more about our services, please contact Bestar.