MAS has proposed transitional arrangements for existing Registered Fund Management Companies (RFMC) consequent to the intended repeal of the RFMC regulatory regime.


Proposed Transitional Arrangements for Repeal of Registered Fund Management Companies Regime

April 25, 2024

The Monetary Authority of Singapore has proposed arrangements for a smooth transition for existing Registered Fund Management Companies (RFMC) consequent to the intended repeal of the RFMC regulatory regime.  The regime repeal and transitional arrangements will be set out in subsidiary regulations to the Securities and Futures Act 2001.

Background of the RFMC Regime

The RFMC framework was established after the Exempt Fund Managers (EFM) regime was repealed to improve MAS' regulatory control over fund managers, thereby aiding some EFMs transition into a fully regulated regime.   

The admission criteria and business conduct requirements of RFMCs and licensed fund management companies (LFMCs) serving only accredited or institutional investors (A/I LFMCs) are mostly similar. However, as RFMCs are limited to serving up to 30 accredited or institutional investors and to managing not more than S$250million of assets (AUM Cap), there are some differences in financial, reporting and appointment requirements for RFMCs and A/I LFMCs.

Repeal of the RFMC Regime

As many RFMCs have changed status to become LFMCs, MAS has taken the view that the RFMC framework has served its purpose of transitioning EFMs. Accordingly, MAS will repeal the RFMC regime from 1 August 2024 to harmonise and simplify the requirements for fund management companies. It has already ceased accepting applications for registration of RFMCs since January 2024.

Proposed Transitional Arrangements

MAS intends to implement the following transitional arrangements for existing RFMCs:

Licensing Process
  • An existing RFMC that wishes to continue its operations must submit Form 1AR between 1 April 2024 and 30 June 2024 to apply for a capital markets services (CMS) licence for fund management to become an A/I LFMC.
  • The RFMC must have carried on business in fund management activities in the 6 months preceding the submission of the application, unless the RFMC has been registered for less than 6 months.
  • No application fee is payable.
  • MAS will review all applications within 1 month from submission.
  • Exempt representatives will become appointed representatives on the issuance date of the CMS licence, if granted.
  • RFMCs must ensure that representatives meet the minimum entry and examination requirements prior to licensing.
Regulatory Requirements
  • An existing RFMC must comply with existing regulatory requirements for RFMCs until it is licensed.
  • The A/I LFMC regulatory requirements will immediately apply once an RFMC is licensed.
MAS Written Directions
  • MAS written directions and/or specific conditions issued to RFMCs will continue to apply an RFMC is licensed.
  • Managed assets of RFMCs that transition to A/I LFMCs will still be capped at S$250 million. However, there will be no cap on the number of investors or funds managed.
  • MAS may consider an A/I LFMC’s request to lift the AUM Cap after considering certain factors, including the A/I LFMC’s regulatory compliance record, its internal controls, risk management and compliance arrangements, the stability of its key personnel, and extent and nature of changes to its business model and investment strategy.


Existing RFMCs that wish to continue their operations should be mindful of the transition deadlines and take the necessary steps to comply with the regulatory requirements applicable to licensed fund management companies.

For More Information

OrionW regularly advises clients on financial services regulatory and licensing matters. For more information about compliance with Singapore laws andr egulations, or if you have questions about this article, please contact usat

Disclaimer: This article is for general information only and does not constitute legal advice.


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