The new year starts out with a bang of reporting, as every year: A/I LFMCs must submit their nil misconduct declarations (unless they reported misconduct during the previous calendar year) and their quarterly reports by 14 January 2025. Moreover, the Monetary Authority of Singapore (“MAS”) has issued its joint MAS-MOM Joint Manpower Data Collection 2025, which financial institutions are to submit by 28 February 2025.

On to regulatory changes: The MAS issued an update to its Guidelines on Licensing and Conduct of Business for Fund Management Companies in December 2024. In this update, the MAS highlights examples of conflicts of interest and options for their mitigation, such as fees to external parties, co-investments, or the management of funds with overlapping strategies. In addition, the MAS continued its move to forms in MAS-Tx. You should check on the current way to submit notifications before making your submission.

Finally, we want to highlight the MAS’ expectation for financial institutions to review accredited investors who qualified based on their holdings of digital payment tokens (“DPTs”). As per A1 of the Frequently Asked Questions (“FAQs”) on the Definition of Accredited Investor and Opt-in Process, a haircut of at least 50% to the market value must be applied to an individual’s holdings of DPTs or a maximum value of SGD 200,000, whichever is lower. The MAS expects financial institutions to reassess their customers who qualified as accredited investors based on the DPT holdings by 4 July 2024 (A2 FAQs on the Definition of Accredited Investor and Opt-in Process).

We hope that our updates continue facilitating your compliance in 2025 and wish you a Happy New Year!