The Financial Institutions (Miscellaneous Amendments) Act 2024 prompted the Monetary Authority of Singapore (“MAS”) to publish a flurry of amendments, most of which were updated forms.

A focus of the MAS’ updates has been on the procedures to acquire a holder of a capital markets services (“CMS”) licence, such as a licenced fund management company restricted to servicing qualified investors, namely accredited investors and institutional investors (“A/I LFMC”). The MAS updated its FAQs on the Licensing of Fund Management Companies to include the procedures to acquire a regulated fund management company, updated the “Application for Approval to Obtain Effective Control of a CMS Licence Holder under section 97A(2) of the Securities and Futures Act” and released a circular to notify capital markets services (“CMS”) licence holders of these updates. Notably, the computation examples for determining effective control (per sec. 97A(6)(a)(i) and (ii) of the SFA) have been revised in paragraph 3.1 of the application form (pages 3–6 of the form). All CMS licence holders should review their list of existing persons with effective control and submit the required information via FormSG by 1 August 2025.

In addition, the MAS updated the Notice SFA 04-N11 Reporting of Misconduct of Representatives by Holders of Capital Markets Services Licence and Exempt Financial Institutions, the Guidelines on Outsourcing (Financial Institutions other than Banks), and the Guidelines on Licensing and Conduct of Business for Fund Management Companies. There are no material changes to the notice and guidelines. Similarly, the updated forms will only impact financial institutions as and when they need to use them. The Compliance Toolkit for Approvals, Notifications and Other Regulatory Submissions to MAS for Fund Managers provides updated instructions on what forms to use.