When a licensed fund management company (LFMC) in Singapore hires a portfolio manager, relationship manager, analyst, dealer or anyone who markets its funds, that person generally has to be notified to MAS as a representative before they do any regulated work. The company lodges a notice through MAS’s Corporations and Representatives (CoRe) system, certifies that the individual is fit and proper, and the person may act only once their name appears on MAS’s public register of representatives. Competency, fit and proper and ongoing notification rules then apply for as long as they stay in the role.
Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.
This guide is written for founders, directors and compliance leads of smaller licensed managers who are building a team. It explains who needs to be appointed, which type of appointment fits a new hire, the checks the company must carry out, what has to be filed when people change roles or leave, and why the position is different for a single family office relying on MAS’s licensing exemption.
Which staff in a fund management company must be representatives?
MAS’s FAQs on the licensing of fund management companies state that the representative notification regime applies to every individual who conducts fund management, or other regulated activities that are integral to fund management. In a typical firm, MAS says that people engaged in portfolio management, client servicing, business development, marketing, research and dealing are generally required to be appointed.
Two points often surprise new managers. First, staff who market funds managed by the firm or its related corporations are notified as representatives for fund management, not for dealing in units of a collective investment scheme, because MAS treats marketing your own funds as part of fund management. Second, an individual who deals only for funds managed by the LFMC is appointed for fund management, while a central dealer who also deals for funds managed by related corporations needs an appointment for dealing in capital markets products.
| Role in the firm | Usually needs appointment? | Regulated activity notified |
|---|---|---|
| Portfolio manager, chief investment officer | Yes | Fund management |
| Relationship manager, investor relations, business development | Yes, where they service or solicit clients | Fund management |
| Research analyst supporting investment decisions | Generally yes | Fund management |
| Dealer trading only for the LFMC’s own funds | Yes | Fund management |
| Central dealer trading for related corporations’ funds | Yes | Dealing in capital markets products |
| Finance, HR, IT and pure operations staff | Not usually, if they carry out no regulated activity | Not applicable |
The test is what the person actually does, not their job title. A “chief operating officer” who also meets investors and pitches the fund is doing regulated work.
Appointed, provisional or temporary: which appointment fits the hire?
MAS recognises three types of representative, each lodged on a different form through CoRe.
| Type | Form | Who it suits | Key conditions published by MAS |
|---|---|---|---|
| Appointed representative | Form 3A | Most hires, including local staff | Must meet the entry, examination and fit and proper requirements before appointment |
| Provisional representative | Form 3B, then Form 3D | Experienced professionals relocating to Singapore | At least 3 years of relevant experience; currently or recently regulated overseas for at least 12 months in a comparable regime; 3-month grace period to complete the examinations |
| Temporary representative | Form 3C | Staff of a related overseas entity visiting for a short assignment | Not residing in Singapore; at least 5 years of relevant experience; regulated overseas; appointments in blocks of up to 3 months, totalling no more than 6 months in any 24-month period |
A provisional representative can work during the grace period, but the company must lodge Form 3D within the three months confirming the examinations are passed, and the person’s entry on the register must change to appointed representative. If that does not happen, the provisional status lapses. For both provisional and temporary representatives, the principal gives MAS an undertaking about supervising them properly.
What competency requirements apply in 2026?
Since 1 April 2024, the competency rules are in MAS Notice SFA 04-N22 on Competency Requirements for Representatives of Holders of Capital Markets Services Licence and Exempt Financial Institutions. It replaced the older Notice SFA 04-N09, and earlier module passes are mapped to the new modules. In outline, the notice requires an appointed representative to:
- be at least 21 years old;
- meet minimum academic qualifications set out in the notice, which are benchmarked to GCE “O” Level passes with some alternatives based on experience;
- pass the CMFAS examination modules listed for fund management, currently the Rules, Ethics and Skills module for fund management (RES3) and CM-EIP, unless an exemption applies; and
- complete continuing professional development each calendar year, which for a representative with the same principal for the whole year is 6 core hours on ethics or rules and regulations accredited by IBF and 3 supplementary hours of relevant training.
The notice contains a specific exemption from the CMFAS examination requirements for individuals who manage funds only for accredited investors, institutional investors, or funds offered only to those investors or only outside Singapore. Many boutique managers serving accredited and institutional investors fall within it. The age, academic, fit and proper and CPD requirements still apply, and the principal must certify and ensure that each representative meets them.
What checks must the company do before lodging the notice?
When lodging Form 3A, 3B or 3C, the company certifies to MAS that the individual is fit and proper. MAS’s Guidelines on Fit and Proper Criteria (FSG-G01) look at honesty, integrity and reputation, competence and capability, and financial soundness. The certification is the company’s responsibility, so the hiring file should show how each criterion was checked rather than relying on the candidate’s own declaration. Our guide to the fit and proper criteria explains the three areas in more detail.
MAS Circular CMI 01/2011 sets out due diligence and documentation expected for appointments, including checking with previous employers about dismissals and adverse records. Separately, in December 2023 MAS confirmed that it would mandate reference checks between financial institutions, covering a five-year lookback and requiring firms to respond to requests within 21 calendar days. Check the current MAS notice on reference checks for the exact scope and forms that apply to your firm.
Also confirm the candidate is not still listed for another principal. MAS’s policy is one representative, one principal, except where the principals are related corporations. A new employer must file its own notice even if the person was previously a representative elsewhere.
Hiring steps, from offer to first client meeting
- Map the role. List the activities the person will perform and decide whether each is regulated and under which activity.
- Choose the appointment type. Appointed, provisional or temporary, based on residence, experience and overseas regulatory status.
- Run due diligence. Identity, qualifications, CMFAS passes or exemption basis, employment history, reference checks, credit and litigation searches, and any regulatory history abroad.
- Prepare the fit and proper certification and have the responsible officer review the file.
- Lodge the notice on CoRe and pay the lodgement fee.
- Wait for the register entry. MAS’s FAQs state that only individuals listed on the public register may carry out the regulated activities. Until then, keep the hire away from client-facing and investment work.
- Diarise follow-ups. Form 3D deadline for provisional representatives, CPD tracking and annual fees.
Documents to keep on the hiring file:
- signed offer letter and role description listing regulated activities;
- passport or NRIC copy and residential status, plus work pass details for foreign hires;
- academic certificates and CMFAS result slips, or a written note of the exemption relied on;
- CV with verified employment history and reference check responses;
- evidence of overseas licensing for provisional or temporary representatives;
- fit and proper declaration, search results and the reviewer’s sign-off;
- CoRe acknowledgement and a screenshot of the register entry once it appears.
What must be filed after appointment?
| Event | Filing | Timing stated by MAS |
|---|---|---|
| Representative takes on another type of regulated activity | Form 6 | Before the new activity starts |
| Change in the representative’s particulars | Form 16 | Representative tells the company within 7 days; company lodges within 14 days of the change |
| Representative leaves or stops acting | Form 8 | No later than the next business day |
| Company ceases fund management business | Form 7 | Not later than 14 days after cessation |
A representative also ceases automatically if they have not acted for a continuous period of one month and the principal has not notified MAS, if MAS revokes the status, or if the principal’s licence lapses or is revoked. MAS currently lists a lodgement fee of S$200 for each new lodgement and an annual representative fee of S$700 or S$200, depending on the regulated activities conducted. Annual fees are charged while the representative remains on the register.
What if someone works before they are on the register?
Allowing an unlisted person to manage portfolios or meet investors is a serious compliance failure. The Securities and Futures Act requires individuals carrying out regulated activities for a licence holder to be properly appointed, and MAS can take action against both the firm and the individual, including revoking representative status or issuing prohibition orders. It also creates a problem the next time the firm certifies to MAS that its controls work. If it happens, stop the activity, record what was done and for which clients, and take advice on whether and how to report it to MAS.
How is this different for a single family office?
A single family office (SFO) that operates under the licensing exemption in paragraph 5(1)(ba) of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations is not a capital markets services licence holder. MAS’s FAQs describe the representative notification framework as applying to individuals acting for licence holders and specified exempt financial institutions such as banks, so SFO investment staff are not lodged on the public register in the same way.
That does not mean anything goes. The SFO must keep meeting every condition of the exemption, including the transition steps described in our article on the 15 June 2027 class exemption deadline. If the family office starts managing money for people outside the family, it may need a licence, and the representative rules then apply from the first hire. A family office applying for a tax incentive will also have its own investment professional headcount to meet, explained in our guide to meeting the MAS investment professional headcount.
Example: A newly licensed manager serving accredited investors hires a portfolio manager relocating from Hong Kong, who has been licensed there for four years, and a local relationship manager with no prior industry role. The portfolio manager could be lodged as a provisional representative and start work once listed, with Form 3D due within three months. The relationship manager must meet the age, academic and fit and proper requirements and be lodged as an appointed representative; if the firm manages funds only for accredited and institutional investors, the CMFAS exemption in Notice SFA 04-N22 may apply, but both must complete annual CPD. This is a hypothetical illustration only.
If you are still choosing between licence types, our retail versus accredited investor LFMC guide sets out the differences, and the CMS licence guide covers the wider licensing framework.
Frequently asked questions
Do non-executive directors need to be appointed as representatives?
The regime turns on whether an individual conducts regulated activities. A director who only sits on the board and does not manage portfolios, service clients or market funds is not appointed merely because of the directorship. Directors are still assessed for fitness and propriety under the licence conditions.
Can a representative act for two fund managers at the same time?
Generally no. MAS’s policy is that individuals on the public register may not concurrently act for more than one principal, unless the principals are related corporations.
Our new hire was a representative at her last firm. Do we still need to lodge?
Yes. MAS’s FAQs state that a new principal must notify MAS of its intention to appoint the individual, even if a previous principal had appointed them for the same activity.
How can investors check whether someone is a representative?
MAS publishes a public register showing each representative’s status, principal and regulated activities. It can be searched by name or representative number, and investors are encouraged by MAS to check it.
Do we have to notify MAS when an analyst resigns?
Yes. Lodge Form 8 through CoRe no later than the next business day after the person ceases to act. Relying on automatic cessation after one month is not a substitute for filing.
Need help keeping your fund management team records in order?
If your company is building a fund management team or reviewing its representative records, contact the Raffles Corporate Services team at [email protected] or on WhatsApp at +65 8501 7133. We can maintain your corporate registers, board resolutions and hiring documentation, keep a calendar of filing and renewal dates, and coordinate with the regulatory compliance advisers and the Singapore law firms on our panel who handle MAS licensing matters. Raffles Corporate Services is not licensed by MAS, and this article is general information, not legal or regulatory advice.
The Raffles Corporate Services Editorial Team, Raffles Corporate Services