FAQs on the Licensing and Registration of Fund Management Companies

The Monetary Authority of Singapore, MAS, has issued updated frequently asked questions (FAQs) in connection with the licensing and registration of fund management companies. The FAQs provide guidance on the requirements and procedures in connection with an application to be a fund management company and the appointment of representatives to carry out fund management activities. The FAQs thereby cover issues such as the registration and licensing requirements, the application and registration procedure, or the notification requirements in relation to representatives of the company.
In this latest update, FAQ 20 was amended to read as follows – as quoted:
FAQ 20: Processing Time – How long would MAS take to process a registration or licensing application?
MAS expects to take up to 6 months to review FMC applications which are complete and by applicants that meet all admission criteria. Applications may take longer if the applicant does not fully meet relevant admission criteria, has unique and complex business models, or does not submit all necessary forms, information and documents in the initial application. The applicant should also expect a longer review period if it makes significant changes to its initial application. MAS may require a fresh submission in such situations.
An in-principle approval (“IPA”) is issued to successful applicants at the conclusion of our review process. Applicants have up to 6 months to fulfil requirements set out in the IPA. These requirements typically relate to provision of undertakings, topping up of share capital or formalising the appointments of certain key personnel. The timeline for this phase depends on how quickly the applicant can fulfil the requirements. MAS reserves the right to rescind the IPA if the applicant does not fulfil the requirements within the timeline, or if there are changes to the applicant’s business plan and/or key persons after IPA has been issued. At its discretion, MAS may extend the IPA by a further 3 months if there are strong reasons to do so.
MAS reserves the right to terminate the processing of an application where the applicant is unable to meet the admission criteria, when there are significant information gaps or inconsistencies, or when the applicant is unable to satisfactorily address MAS’ queries in a timely manner. The applicant may re-submit a fresh application to MAS when it is ready to do so.