Why pay an adviser if you can apply yourself?

In our experience, quotes for professional licensing support can range from S$25,000 to S$50,000, depending on the scope. These are advisory fees, separate from the fees payable to MAS.

Now, a fund manager or CEO could look at the MAS guidelines and think: “Wait a minute. Why don’t I read the requirements, fill in the application, answer MAS’s questions and do this myself?”

Your company can submit its own application through MAS’s online licensing system.[1] The question is whether you have the time and expertise to prepare it and work through the review.

Completing the form is only part of the job. You also need to explain the people, ownership arrangements and investment strategy behind the proposed business.

An experienced licensing adviser should help you anticipate pitfalls before the initial submission. That might mean identifying a gap in the team’s experience, an unsuitable appointment or an outside business interest that needs closer examination. Their job is to explain those issues to you, the CEO, so that you can make informed decisions before submitting.

Even if you engage the best advisers and lawyers and pay top dollar, they cannot guarantee a successful application. Fundamentally, much depends on whether the proposed business and the people running it meet the admission criteria in the first place.[2]

How long does a MAS fund management licence application take?

MAS expects to take up to six months to review complete applications from applicants meeting all admission criteria. This is not a guaranteed end-to-end timeline. Incomplete information, complex business models or significant changes during the review can extend the process. Successful applicants may also need additional time to fulfil their in-principle approval conditions before receiving the licence.[3]

Meanwhile, rent, salaries and other commitments may continue. Prospective investors may also be waiting for your launch.

Finding out several months into the process that a key appointment or ownership arrangement needs changing can be expensive. It can disrupt the whole roadmap, not just the application timetable.

In other words, quite a few things need to line up for a smooth application. The guidelines are not a checklist that guarantees approval once every box is ticked. Work through the obvious gaps before committing to a launch date.

Minimum directors, CEO and Singapore staffing

For a start, the main staffing baselines for an A/I LFMC are set out below. These are minimum admission criteria, not a complete staffing plan for every business.[2]

Appointment A/I LFMC baseline
CEO At least five years of relevant experience, including managerial or supervisory experience; employed full-time in the business and resident in Singapore.
Directors At least two, each with at least five years of relevant experience, including managerial or supervisory experience.
Executive directors At least one. Each must work full-time in the business and reside in Singapore. At least one must have five years of portfolio management experience relevant to the proposed investment activities, asset classes and markets.
Relevant professionals At least two, each with at least five years of relevant experience, employed full-time and based in Singapore.
Representatives At least two full-time representatives residing in Singapore, meeting the applicable entry and competency requirements.

The CEO can also be an executive director, relevant professional and appointed representative, provided the individual meets the requirements for each appointment. You do not need a separate person for every title.[2]

However, appointing a second director who only provides non-executive oversight does not, by itself, fill the second full-time professional and representative positions.

A non-executive director is not expected to run daily operations, but should make a meaningful contribution to board oversight. The appointment is more than having someone available for the occasional board meeting.[4]

Relevant experience means more than years on a CV

The number of years matters, but so does what you actually did during those years.

Suppose your experience was primarily in real estate investment management, and you now propose to set up a hedge fund investing in credit and bond markets. You should be ready to explain who in the proposed team has the experience to manage those assets and their risks.

MAS assesses experience against the proposed roles and business. The people overseeing the investment activities need, collectively, relevant experience in the asset classes, markets and strategies the company intends to pursue. For private equity and venture capital strategies, relevant experience may also include experience in the industries of the investee companies.[2]

Experience investing your own money or family money is not treated as relevant experience for a business seeking to manage third-party funds. Where investment-management experience was gained at an unregulated entity, you should be prepared to substantiate it.[2]

Prepare CVs that explain responsibilities, investment mandates, asset classes, management experience and dates. A list of impressive job titles can leave quite a few questions unanswered.

Minimum base capital and your operating budget

An A/I LFMC must maintain minimum base capital of S$250,000. It must also meet the applicable risk-based capital requirement, including maintaining financial resources of at least 120% of its total risk requirement.[2]

This does not mean S$250,000 must sit untouched in a bank account. Base capital is a regulatory calculation, not simply the bank balance. Losses can reduce it: MAS’s financial-return form and capital FAQs expressly account for this.[5]

That distinction does not make the minimum optional. You need enough funding to keep meeting the capital and financial-resources requirements as the company operates.

For example, starting with S$300,000 of qualifying base capital would leave only S$50,000 above the minimum before losses or other relevant changes. That is not an estimate of what will fund your first year.

Work out what rent, salaries, professional fees and other overheads are likely to cost during the application period and after launch. Your funding plan should also account for the possibility that management fees arrive later than expected.

Outside business interests and conflicts of interest

In our experience, outside business interests can generate quite a few questions during an application. You may already have people with the right years of experience, but that does not resolve how they will divide their time between the applicant and their existing businesses.

The CEO and executive directors are expected to work full-time in the business and reside in Singapore. If you currently have another full-time job, think through when and how you will move into the proposed role.[2]

Directorships, employment positions and shareholdings elsewhere need to be examined for competing commitments and conflicts. The issue is not simply how many titles you hold, but whether those interests affect your ability to run the Singapore business and act in investors’ interests.

For example, a proposed fund might invest in a business owned by a director or a connected person. You need to assess the conflict, make the required disclosures and explain how it will be managed. MAS may require CEOs or executive directors to divest outside interests where conflicts or reputational risks cannot be adequately mitigated.[2]

A clean application is not about making your outside interests look as though they do not exist. Be clear about what you own, the roles you hold and the time each commitment takes. Work through the disclosure questions in the current application rather than rely on a blanket percentage threshold.[6]

Your business plan and control arrangements

MAS will also look at your business plan, target investors, investment strategy and risk-management arrangements. The plan should be supported by the experience and expertise of the proposed team.[3]

Explain who you intend to manage money for, which assets and markets you will invest in, and how investment decisions will be made. Where you propose an investment committee, be clear about its members, responsibilities and decision-making authority.

You should also work through the arrangements for compliance, risk management, valuation, custody and audit. These need to suit the business you are proposing, rather than simply appear as headings in an application.[2][3]

Outsourced compliance support may be appropriate where it meets the applicable requirements. Risk management is a separate function and needs appropriate segregation and independence from portfolio management. Outsourcing does not remove the CEO’s and directors’ ultimate responsibility for compliance.[2]

The practical questions are straightforward: who performs each function, who checks their work, and how do concerns reach management?

Ownership, overseas groups and Singapore presence

If the proposed company belongs to an overseas group, prepare the ownership chart, relevant financial statements, regulatory status and track record of the entities involved. Explain what the Singapore company will do and what support it will receive from the group.[1][3]

For a fund manager that is not part of an established business group and is owned by individual shareholders, MAS expects the CEO and executive directors collectively to hold and maintain more than 50% of its effective voting interest. The arrangements must allow them to exercise effective control over the business.[2]

MAS may consider alternative measures case by case. Work through this before finalising your shareholding structure and shareholder agreements, rather than after discovering that they undermine the proposed management team’s control.[3]

The fund manager should also be a Singapore-incorporated company with a permanent physical office that is dedicated, secure and accessible only to its directors and staff.[2]

Fit and proper checks

MAS assesses honesty, integrity and reputation, competence and capability, and financial soundness. This is not limited to counting years of experience.[7]

Relevant criminal, regulatory, disciplinary or civil matters need to be disclosed and explained as required. A past issue does not automatically mean every application will fail: its seriousness, relevance, surrounding circumstances and the passage of time can matter.[7]

If there is something in your background that may raise questions, tell your adviser early. Bring the relevant documents and explain what happened. Finding out halfway through the application helps nobody.

What to prepare before engaging an adviser

You do not need a finished application before speaking to an adviser. Start with:

  • A summary of your investment strategy, intended investors and proposed business model.
  • CVs and proposed roles for your CEO, directors and investment team.
  • An ownership and group structure chart, including voting rights and proposed shareholder arrangements.
  • Details of outside employment, directorships and business interests.
  • An operating budget, funding plan and financial projections.
  • An outline of compliance, risk-management and operational arrangements.
  • Any known gaps, relevant background matters and your intended launch timetable.

Bring these to your first meeting and ask the adviser to identify the gaps, explain what work they will handle and spell out what the quoted fee includes.

If you have read through the above and believe the requirements could reasonably be met, Advisors Assemble can help you assess the proposed setup, address outstanding issues and prepare the application.

To discuss your plans, contact [email protected].

If your A/I LFMC is already operating and needs help reviewing its current arrangements, see our ongoing fund management compliance support. We agree that work separately from application preparation.

This guide provides general information for A/I LFMC applicants. It is not an exhaustive statement of applicable requirements or a guarantee of licensing approval.

Sources

  1. [1]

    Monetary Authority of Singapore, Fund Management Licensing, and Capital Markets Services (CMS) Licence. For the A/I LFMC staffing criteria, refer to the specific fund-management guidelines in source 2 rather than the general CMS-page summary. ↩ ↩2 ↩3

  2. [2]

    Monetary Authority of Singapore, Guidelines on Licensing and Conduct of Business for Fund Management Companies, SFA 04-G05, revised 3 September 2025. Relevant provisions: paragraphs 1.2–1.3 (scope); 3.7–3.10 (competency and external involvements); 3.11–3.12 (ownership and office); 3.13–3.18 (capital, compliance, risk and audit); 4.1.1–4.1.3 (custody, valuation and conflicts); Appendix 1 (staffing); Appendix 2 (compliance arrangements). ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12

  3. [3]

    Monetary Authority of Singapore, FAQs on the Licensing of Fund Management Companies, updated June 2026, questions 20–22 (management control, processing time and submission quality). ↩ ↩2 ↩3 ↩4 ↩5

  4. [4]

    Monetary Authority of Singapore, FAQs on the Licensing of Fund Management Companies, updated June 2026, questions 12–13 (director roles and relevant experience). ↩

  5. [5]

    Monetary Authority of Singapore, Form 2: Statement of Financial Resources, Total Risk Requirement and Aggregate Indebtedness, section I; and FAQs on Risk Based Capital Adequacy Requirements, revised 25 March 2026, question 10. ↩

  6. [6]

    Monetary Authority of Singapore, Form 1: Application for a Capital Markets Services Licence. Follow the current online application and its disclosure instructions; this guide does not prescribe a universal threshold for outside interests. ↩

  7. [7]

    Monetary Authority of Singapore, Guidelines on Fit and Proper Criteria, FSG-G01, revised 30 May 2025, particularly paragraphs 8–9 and the applicable criteria in paragraphs 13–15. ↩ ↩2