You are currently viewing Update Feb 2024- Navigating Change: MAS Updates Guidelines on Licensing and Business Conduct for Fund Management Companies

Update Feb 2024- Navigating Change: MAS Updates Guidelines on Licensing and Business Conduct for Fund Management Companies

The MAS compliance officer training requirements were updated on 23rd February 2024.  The Monetary Authority of Singapore (MAS) revised its Guidelines on Licensing and Business Conduct for Fund Management Companies [SFA 04-G05]. This update builds on the broader changes MAS introduced in November 2023. We covered those changes in our earlier article on the revised Guidelines. This guideline provides fund managers with the requirements necessary to qualify as fund managers, including MAS compliance officer training expectations. It also sets out how to supervise and regulate their businesses.

The Guidelines on Licensing and Business Conduct for Fund Management Companies [SFA 04-G05] set out the pre-requisite criteria and application procedures. They also cover ongoing business conduct requirements for Licensed Fund Management Companies (LFMCs), Venture Capital Fund Managers (VCFMs), and Registered Fund Management Companies (RFMCs).

MAS Compliance Officer Training Requirements: What Changed

Key Changes Previous Guideline Revised Guideline
Compliance Arrangements The revised guidelines (29 November 2023) required in-house compliance officers to be familiar with the rules and regulations applicable to the fund management company (FMC). They also needed to be regularly and appropriately trained on them. Where an FMC has an in-house compliance officer, MAS expects the individual to have relevant experience, for example in regulatory compliance, audit, or risk management. They should also be familiar with, and regularly and appropriately trained on, the rules and regulations applicable to the FMC. The revised guideline (23rd February 2024) still requires in-house compliance officers to be familiar with the rules and regulations applicable to the FMC. They must also be regularly and appropriately trained on them. However, it provides additional information on what an FMC should do when queries arise. This includes where and how they can find this information.

‘As a matter of principle, an FMC should consult its in-house compliance officer or third-party service provider. This applies whenever it has queries on the applicability of rules and regulations. If there is a need to seek clarification from MAS, the FMC should set out a detailed assessment of the specific regulatory query. This should clarify if the query is wants clarified or approved. MAS has information resources on our website. These assist FMCs in complying with the relevant requirements. These are set out in the Compliance Toolkit for Approvals, Notifications and Other Regulatory Submissions to MAS for Fund Managers. They also appear in the FAQs on the Licensing and Registration of Fund Management Companies. These resources cover aspects such as regulatory filing requirements and entry requirements for representatives.’

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