MAS Revises Guidelines for Fund Management Company Directors, CEOs and AUM

Background

On 3 September 2025, the Monetary Authority of Singapore (MAS) released a revised version of Guideline SFA 04-G05 on Licensing and Conduct of Business for Fund Management Companies (FMCs). These Guidelines set out the admission criteria, business conduct standards and ongoing requirements for licensed FMCs, Accredited/Institutional LFMCs (A/I LFMCs) and Venture Capital Fund Managers (VCFMs).

Key Updates

Managed Assets:

–        Revised definition in determining value of Assets Under FMC’s Management.

–        Assets under an FMC’s management now includes:

a)     moneys and assets contracted to, or drawn down by the FMC, and are under the discretionary authority granted by the customer to the FMC,

b)     moneys and assets contracted to the FMC, and are under the nondiscretionary authority granted by the customer to the FMC,

c)     moneys and assets contracted to the FMC, but which have been subcontracted to another party and for which the other party is carrying out fund management, whether on a discretionary authority granted by the customer or otherwise.

Executive Directors:

–        MAS clarified that each director should have at least 5 years of relevant experience.

–        Explicit understanding that all the Executive Directors should be involved full-time in the day-to-day operations of the FMC and be resident in Singapore.

–        All Executive Directors must have adequate management experience relevant to their specific responsibilities in the FMC

VCFMs:

–        Revised criteria and new guidelines on key personnel, including that a CEO must be appointed.

–        Change in tone of words from “shall” to “must”, meaning that the VCFMs are required to comply with the requirements in the Guidelines.

What’s Next?

  • FMCs should review operational arrangements (e.g. duties and requirements of Executive Directors) to ensure compliance with the revised Guidelines.
  •  VCFMs should ensure that the CEO is employed full-time and resident in Singapore.
  • New FMCs applying for license or FMCs appointing new Executive Directors should ensure that the person hired for the roles are suitable.

How Can We Help?

Capital Governance assists fund managers in:

  • Capital Markets Services Licensing applications
  • Reviewing governance, ownership, and competency of key personnel.
  • Strengthening compliance, risk management, and audit frameworks.

And more…

Contact Us today to discuss how we can provide the risk and compliance advisory solutions for you. Find out more here.