Repeal of RFMCs and Transition to CMS license

Aspect

Description

Application Requirement

Use prescribed form 1AR (Annex 1 of the Consultation paper)

Eligibility for CMS License

Must actively engage in FM activities six months preceding the application & submit the form within the timeline

MAS Response Time

Within a month of submission.

Transition of Representatives

Exempt representatives of RFMCs transition to appointed representatives under the CMS regime

Regulatory Review

MAS will review known regulatory concerns or issues regarding the fitness and propriety of the RFMC, its directors, shareholders, or staff.

Application Fee Waiver

Waived application fees and fees for notification of existing representatives

Upon licensing, pro-rated CMS annual corporate license fee & representative fees will apply.

Continued Restrictions

1. Transitioning RFMCs to A/I LFMCs subject to S$250 million asset management cap
2. Require MAS review for higher limits
3. Maintain risk-based capital,
4. Ensuring financial resources do not fall below 120% of the total risk requirement

Number of investors

There will be no cap on the number of investors or funds managed

Reporting Requirements

Transitioned A/I LFMCs comply with reporting requirements & seek MAS’s prior approval for significant changes like shareholders and key appointment holders & new representative appointments.

A/I LFMCs familiarize themselves with regulatory requirements & seek professional compliance service providers if needed. Also, refer to the Compliance Toolkit of LFMCs for guidance.