Singapore – CM AM

Update BRP Country Manual Asset Management

Singapore

BRP has published its latest update concerning

the Country Manual Asset Management

for Singapore

Definitions & Concepts, Regulatory Overview and Behaviour Template

Material changes

The changes/modifications are as follows:

Finally, the (active) marketing of investment strategies is now also permitted if (indirectly) conducted with/via a locally licensed entity in connection with the marketing of funds/structured products. However, the activities to be carried out by the firm should be coordinated with the locally licensed entity. Accordingly, the CM AM BT now provides the answer “Grey zone/YES – Permitted in relation to the marketing of funds/structured products. Activities to be performed by the Company should be coordinated with the locally licensed entity.” for the relevant onshore scenario.

Brand advertising (without mentioning specific information about strategies, financial products and/or investment services) is not a licensable activity and therefore generally permitted if performed exclusively to Institutional Clients or in compliance with the marketing restrictions. The Country Manual Asset Management Behaviour Template (CM AM BT) therefore now provides the answer “Grey zone/YES – Permitted if performed exclusively to Institutional Clients or in compliance with the marketing restrictions” in all scenarios.

It is highlighted that the handling of contracts, agreements, subscription forms or transaction documents (including their signature) is not permitted onshore in Singapore (at target). The CM AM BT therefore now provides the answer “NO” in the relevant onshore scenario.

Activities based on a reverse solicitation or responding to an RFP into Singapore (remote) by the foreign (non-licensed) investment firm are generally permitted on a cross-border basis into Singapore (remote) provided that the prospectus and product registration requirements are complied with (unless a private placement exemption applies), with no restrictions on services. The CM AM BT therefore provides the answer “Grey zone/YES – Permitted, provided that the prospectus and product registrations requirements are complied with (unless a private placement exemption applies). No restrictions for services.” in the relevant remote scenarios.

Non-material changes

Some comments and content have been slightly reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, March 24^th, 2025