On 7 June 2024, the Monetary Authority of Singapore (MAS) published an updated version of:

(i) the Guidelines on Licensing, Registration and Conduct of Business for Fund Management Companies (‘GLRCB – FMC’); and

(ii) the FAQs on the Licensing and Registration of Fund Management Companies (‘FAQ – LR – FMC’)

Amendments were made to the following provisions :

(i) GLRCB FMC: Appendix 5 – Requirements for Venture Capital Fund Managers – Fund Eligibility; and

(ii) FAQ – LR – FMC: VC Manager Regime – Type of Funds – FAQ 38

The amendments all relate to VCFMs, and clarify the language relevant to the definition of what constitutes a VC / PE fund – for the purpose of defining the regulatory criteria to be met by funds managed by VCFMs.

In particular, the new language makes it clear that the 20% threshold applicable to the investment of committed capital in ‘non-qualifying investments’ is to be computed on a fund-by-fund basis – as opposed to computing it at the level of the manager i.e. across all funds managed by the VCFM.