On 26 December 2012, the Monetary Authority of Singapore (“MAS”) issued a consultation paper relating to proposals to amend the Securities and Futures (Offer of Investments) (Collective Investment Schemes) Regulations 2005 (the “CIS Regulations”).  A copy of the consultation paper can be found here.

The key proposals set out in the consultation paper were for:

  • enhanced disclosure obligations for the prospectuses of authorised and recognised collective investment schemes (i.e. funds marketed to retail investors in Singapore);
  • a new requirement for an information memorandum to be produced and filed in respect of “restricted schemes” (i.e. funds which are marketed under the lighter regulatory regime allowing offers to be made to accredited investors and other specified persons); and
  • the general extension of the regulatory regime for collective investment schemes to closed-ended funds.

Following conclusion of the consultation period in January 2013, MAS published its response to the consultation and amendments to the CIS Regulations on 1 April 2013. With certain clarifications and concessions, the amendments to the CIS Regulations adopt the position set out in the consultation paper. Compliance with the enhanced disclosure requirements for retail funds will require managers marketing such funds in Singapore to update their fund documentation. The amendments to the rules applicable to funds marketed to non-retail investors and to closed-ended funds represent more fundamental changes to the regulatory regime. To read our more detailed briefing, click here.


Herbert Smith Freehills LLP is licensed to operate as a foreign law practice in Singapore. Where advice on Singapore law is required, we will refer the matter to and work with licensed Singapore law practices where necessary.