The RFMC regime was repealed on 1st August 2024.
1. Consequences for ex-RFMCs – Our conversion package
Here is a link to our RFMC > A/I LFMC conversion package.
Converted RFMCs should take into account their new regulatory obligations.
2. Regulatory framework
There are now 3 categories (instead of 4) of licenced fund management companies in Singapore:
- Retail LFMCs
- A/I LFMCs
- VCFMs
On 1st August 2024, the Monetary Authority of Singapore (MAS) issued various publications implementing the consequences of the RFMC regime repeal.
We have looked at the following publications, see our notes below:
(i) Guidelines On Licensing And Conduct Of Business For Fund Management Companies (‘GLCB – FMC’)
- Any reference to the RFMC regime was deleted.
- Appendix 4 providing a list of documents required for licensing is deleted.
- Appendix 5 on VCFM becomes Appendix 4.
- Some formal clarifications were made, for example a licensing application can only be made by a ‘company’, not by a ‘person’.
(ii) FAQs on the Licensing of Fund Management Companies (‘FAQ – LR – FMC’)
- Any reference to the RFMC regime was deleted.
- Some formal clarifications were made, replacing the word ‘entity’ with the word ‘corporation’ in some provisions, e.g. in the sections relating to central dealing and single family offices.
- Also, a VCFM is now clearly characterised as a fund management company.
(iii) Compliance Toolkit for Venture Capital Fund Managers
- No changes since the January 2023 update.
(iv) Compliance Toolkit for Licensed Fund Managers
Amendments were made to the following provisions:
- Any reference to the RFMC regime was deleted.
- Added references to cross-border arrangements (foreign related corporations and foreign offices) and related notifications.
- Updated and clarified notifications requirements re. CEO / Director change of address, suspension of funds dealing, gating and liquidity management tools.
- Various formal updates e.g. methods of submissions to MAS.
(v) Form 23A – Notice of Change of Particulars of a VCFM
- No changes.
(vi) Guidelines on Liquidity Risk Management Practices for Fund Management Companies
- References to the RFMC regime were deleted.
Exocap’s other publications on this topic:
