Exemptions from licensing / registration to conduct fund management activities
Exemptions from registration and licensing depend on the company's scope of activities. Additionally all who manage assets >$250m or serving more than 30 qualified investors must be licenced (registration will not be sufficient).
If the scope of a company’s fund management activities falls within certain categories, it may be eligible for an exemption from licensing or registration to conduct fund management.
Examples of such companies are those that:
• Manage a pool of immovable assets for accredited and institutional investors;
• Manage funds for related corporations; or
• Manage moneys belonging to a single group of related family members.
In certain scenarios, companies may need to apply to MAS specifically for exemption if they do not fall neatly within the pre-defined scope of exclusion. You can find more information on exemptions under section 99 of the SFA and paragraph 5 of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations.
According to MAS (Parliamentary replies)
last revised on 16 November 2012
Fund managers managing assets of more than $250m or serving more than 30 qualified investors are required to obtain a licence from MAS. Those who fall below these thresholds may either apply for a licence or register with MAS. The required base capital ranges from S$250,000 to S$1 million and is tiered, based on the type of clientele served by the manager. For a Registered Fund Management Company (RFMC), the base capital requirement is pegged at S$250,000 to provide a buffer for unexpected costs, arising from turbulent markets or operational shocks.