Reed Smith Client Alerts

Key takeaways

  • MAS this month updated guidelines for fund managers: fund managers are now expected to mitigate conflicts of interest in the best interests of their customers and set up mechanisms to do so.
  • The policies developed to mitigate conflicts of interest should be documented, independently reviewed, and approved by the appropriate authority.
  • Further guidance sets out the revised and expanded scenarios which can give rise to conflicts of interest, along with the good practices to ensure conflict management.

Introduction

On 10 December 2024, the Monetary Authority of Singapore (MAS) issued the updated Guidelines on Licensing and Conduct of Business for Fund Management Companies (Guidelines), which outline MAS’ expectations for fund management companies (FMCs) to put in place measures to mitigate any actual or potential conflicts of interest (COIs). The updated Guidelines are applicable to all FMCs. We highlight below the significant changes to the earlier version of the Guidelines that, in our view, require attention and prompt action by FMCs, as necessary.

Key changes to Guidelines

Prior to the update, the Guidelines provided that FMCs put in place mitigating measures to address any COIs and, where appropriate, disclose any actual or potential COIs to their customers.