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Compliance Toolkit for Licensed Fund Management Companies (LFMCs)

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Source

  • Issuer: Monetary Authority of Singapore (MAS)
  • Act: Securities and Futures Act 2001 (SFA)
  • Version: Issued 2 October 2020, last revised 25 February 2026
  • Document type: Compliance Toolkit

Overview

This toolkit provides Licensed Fund Management Companies (LFMCs) with a reference on common applications, forms, and submissions required under the SFA. It covers applications for MAS approvals, notifications to be submitted, and regulatory submissions (e.g. financial returns).

This toolkit is not exhaustive, and LFMCs are expected to be familiar with all applicable legislation. It excludes reporting obligations outside the SFA and fund-level requirements (e.g. Code of Collective Investment Scheme). Where an LFMC also conducts other SFA regulated activities such as dealing in Capital Markets Products, it should refer to the compliance toolkit for those activities.

Applicability

Licensed Fund Management Companies (LFMCs) holding a CMS licence for fund management.

Key Legislative and Regulatory Requirements

  1. Securities and Futures Act 2001 (SFA) -- Parts IV, V
  2. Securities and Futures (Licensing and Conduct of Business) Regulations (LCBR) (Rg. 10)
  3. Securities and Futures (Financial and Margin Requirements for Holders of CMS Licenses) Regulations (FMR) (Rg. 13)
  4. SF(ECBA)(FRC)R -- Cross-Border Arrangements (Foreign Related Corporations) 2021
  5. SF(ECBA)(FO)R -- Cross-Border Arrangements (Foreign Offices) 2021
  6. Licence conditions imposed on LFMCs
  7. Guidelines on Licensing and Conduct of Business for Fund Management Companies
  8. Notice on Reporting of Misconduct of Representatives by Holders of CMS Licence and Exempt FIs
  9. Notices SFA04-N17 and SFA04-N18 -- Cross-Border Arrangements requirements

Mode of Submission

  • eLicensing: https://elicensing.mas.gov.sg/
  • MAS-Tx portal: https://mas-tx.mas.gov.sg (rep register: https://eservices.mas.gov.sg/rr)
  • CoRe (MAS-Tx): Replaces legacy MASNET portal for representative notifications and financial returns
  • Submissions via FormSG, MAS-Tx or eLicensing: do not encrypt uploaded attachments
  • Use MAS-Tx for due dates, email reminders, and submission copies

Section A: Applications for Approvals from MAS

S/N Requirement Form Deadline Reference Mode
1 Grant of CMS licence for fund management Form 1 Prior to carrying on business as LFMC Section 84 SFA eLicensing
2 Conduct additional regulated activity under SFA Form 5 Prior to carrying on additional activity Section 90 SFA, Reg 11A LCBR MAS-Tx
3 Appointment of CEO or Director Form 11 Prior to appointment / change Section 96 SFA, Reg 12 LCBR MAS-Tx
4 Obtain effective control of LFMC Application under Section 97A(2) SFA Prior to obtaining effective control Section 97A SFA MAS-Tx
5 Change of members/shareholdings (20%+) No prescribed form Prior to change Licence condition MAS-Tx
6 Acquire 20%+ interest in corporation / establish branch No prescribed form Prior to acquisition/establishment Licence condition MAS-Tx
7 Comply with new base capital requirement No prescribed form Prior to commencing/ceasing/changing business Reg 4 FMR MAS-Tx
8 Reduce paid-up share capital No prescribed form Prior to reduction Reg 20 FMR MAS-Tx
9 Disclose inspection reports No prescribed form Prior to disclosure Sections 150A and 150C SFA MAS-Tx
10 Disclose investigation reports (MAS investigation) No prescribed form Prior to disclosure Section 152A SFA MAS-Tx
11 Remove S$250 million AUM restriction Application to review restriction Prior to exceeding S$250M Licence condition MAS-Tx

Section B: Notifications to MAS

B1: Notifications in relation to the LFMC

S/N Requirement Form Deadline Reference
12 Cessation of business Form 7 (with audit certification) Within 14 days of cessation; Immediately for non-commencement after 6 months Section 93 SFA, Reg 11 LCBR
13 Change of name / principal place of business Notice for Change in Particulars Within 14 days from date of change Section 93 SFA
14 Material adverse change to financial position (insolvency, inability to meet obligations, suspended payments) No prescribed form Immediate Section 97C SFA
15 Change in shareholders (<20% control) No prescribed form Immediate Licence condition
16 Execution of agreement for purchase/sale/merger of business No prescribed form 7 days prior to execution Licence condition
17 Resignation of CEO/Director; changes in director particulars, business interests, shareholdings Notice of Change in Particulars As soon as practicable; for (i), no later than 14 days from resignation Licence condition
18 Fitness & propriety concerns (offences, disciplinary actions, breach of laws by officers/reps) No prescribed form Immediate Licence condition
19 Fewer than 2 full-time appointed representatives per regulated activity No prescribed form As soon as practicable Licence condition
20 Significant redemptions and activation of liquidity management tools for CIS (a) Significant Redemption Report; (b) Fund Gating and Suspension Report (a)(i) T+1 for daily dealing CIS (>5% AUM); (a)(ii) T+3 for daily dealing CIS (weekly >10% AUM); various for other frequencies Guidelines on Liquidity Risk Management
21 Cross-border arrangements commencement Form FN Within 14 days of commencement SF(ECBA)(FRC)R, SF(ECBA)(FO)R
22 Changes to cross-border arrangements Form FC Within 14 days from date of change SFA04-N17, SFA04-N18
23 IT security incident (severe/widespread impact) Per Circular on FI Incident Reporting Within 1 hour of discovery (call/email) Section 29(1) FSM Act (FSM-N21)

B2: Notifications -- Financial and Margin Requirements

S/N Requirement Form Deadline Reference
24 Temporary inclusions in financial resources No prescribed form Immediate Reg 2A FMR
25 Base capital falls below prescribed amount No prescribed form Immediate Reg 4 FMR
26 Financial resources fall below total risk requirement No prescribed form Immediate Reg 6 FMR
27 Financial resources fall below 120% of total risk requirement No prescribed form Immediate Reg 7 FMR
28 Preference shares issuance and repayment No prescribed form For issuance: prior; For repayment: 3 months before Reg 21 FMR
29 Qualifying subordinated loan drawdown and repayment No prescribed form Prior to drawdown; prior to early repayment; 1 business day before matured loan repayment Reg 22 FMR

B3: Notifications -- Representatives

S/N Requirement Form Deadline Mode
30 Appointment of appointed representative Form 3A Prior to appointment MAS-Tx
31 Appointment of provisional representative Form 3B Prior to appointment MAS-Tx
32 Appointment of temporary representative Form 3C Prior to appointment MAS-Tx
33 Completion of examination requirements (provisional rep) Form 3D Prior to expiry of specified period MAS-Tx
34 Addition of regulated activities for appointed rep Form 6 Prior to carrying out additional activity MAS-Tx
35 Cessation of representative Form 8 (a) No later than next business day; (b) Immediate MAS-Tx
36 Change of representative's particulars Form 16 Within 14 days of change MAS-Tx

Section C: Regulatory Submissions to MAS

S/N Requirement Form Deadline Mode
37 Quarterly financial returns Forms 1 and 2 Within 14 days from quarter end CoRe (MAS-Tx)
38 Annual audited financial returns and auditor's report Forms 1-6 Within 5 months from FY end CoRe (MAS-Tx) (Forms 1-4), MAS-Tx (Forms 5-6, auditor's report)
39 Misconduct reporting for representatives Report on misconduct Upon discovery; update for significant developments MAS-Tx
40 Annual declaration of nil misconduct Declaration of Nil Return Within 14 days after calendar year end MAS-Tx
41 Cross-border arrangements annual declaration Form FR Within 5 months from FY end MAS-Tx
42 IT incident root cause and impact analysis report Incident Reporting Template Initial: ASAP (max 24 hours); Final: within 14 days MAS-Tx

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