What type of fund management company applies to my business?
According to MAS (Guidelines)
last revised on 11 August 2021
RFMCs [...] carry on business in fund management with no more than 30 qualified investors (of which no more than 15 may be funds or limited partnership fund structures) AND the total value of the assets managed does not exceed S$250 million.
Retail LFMCs [...] carry on business in fund management with all types of investors, without restriction on the number of investors.
Accredited Investor LFMCs [...] carry on business in fund management with qualified investors only, without restriction on the number of qualified investors.
"In most (if not all the cases), the determining factor for the choice between being a CMSL holder for the regulated activity of fund management or a RFMC is the estimated assets under management (“AUM”) of the FMC. If it is estimated that the FMC’s AUM will be close to or more than S$250 million, the FMC will have to apply to be licensed as an A/I LFMC because the total AUM of a RFMC cannot exceed S$250 million. A RFMC can subsequently apply to become an A/I LFMC as its AUM grows and is expected to exceed the relevant threshold."
Note that the types of investors are also different for each fund:
- "Registered FMCs – FMCs with less than S$250 million Assets Under Management (AUM) and which serve not more than 30 qualified investors (of which not more than 15 are funds). Registered FMCs will replace the current category of Exempt FMCs.
- Licensed A/I FMCs (A/I LFMCs) – FMCs with more than S$250 million AUM and that serve only accredited and/or institutional investors.
- Licensed Retail FMCs (R LFMCs) – FMCs with more than S$250 million which serve retail investors"