MAS Amends Its FAQs on the Licensing and Registration of Fund Management Companies

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On 19 September 2016, the Monetary Authority of Singapore (MAS) amended its FAQs on the Licensing and Registration of Fund Management Companies.

The key changes are as follows:

  • A licenced Fund Management Company (FMC) that conducts central dealing activity for funds managed by its related entities must ensure that it has the requisite risk management systems and controls that are commensurate with the scale and complexity of the central dealing function.
  • There is now a clear statement that an FMC is discouraged from appointing the same audit team for providing internal and external audit services except in exceptional circumstances. Where an FMC would like to do so, it should demonstrate to the MAS that the audit firm has appropriate safeguards in place. The FAQs previously simply stated that the FMC should satisfy itself that such appropriate safeguards were in place.
  • A new Q&A has been added explaining the difference between an executive and a non-executive director. It further states that the titles of the directors should appropriately reflect their roles. For example, a non-executive director should not have a designation such as "Executive Director" and vice versa.
  • There is a new Q&A clarifying that the provision of factual information on investment products managed by the FMC or its related corporations is not a financial advisory activity. Factual information in this context refers to information which does not take into account the specific investment objectives, financial situation and the particular needs of any person who may receive the information.
  • The processing time for approval of a registration or licensing application has been extended from 12 weeks to four months, and new documents have been required for the submission.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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