If a bank requests a VCC member register, verify the request and assess the appropriate disclosure. A register not being publicly available does not mean every private information request should be refused or fulfilled without review.
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Coordinate the response through authorised staff, the manager and relevant advisers.
Distinguish public access from a specific request
ACRA’s VCC guidance explains that member lists are not shared with the public and public authorities can request them. A bank’s due diligence request should be assessed in its own legal and contractual context.
Identify what information is requested, why and which entity or relationship it concerns.
Example: an unfamiliar email asks for every investor passport
The sender claims to be helping with account opening. Verify the contact through the bank’s known channel before supplying identity documents. A detailed request can still come through the wrong person or an insecure route.
Prepare a controlled response
- Verified requesting institution and contact.
- Actual purpose and required information.
- Relevant authority and disclosure assessment.
- Current register and accurate supporting records.
- Approved secure delivery channel.
- Record of what was provided and when.
Ask whether the relevant information can be supplied in an appropriately limited form. Do not assume redaction is acceptable without checking the recipient’s actual requirement.
Reconcile before sending
Compare the register with completed subscriptions, redemptions and relevant investor records. Explain discrepancies to advisers instead of altering documents to make a request disappear.
Do not send an old cap table merely because it is easier to locate. The response should reflect the appropriate current record and its actual scope.
Retain access and disclosure controls
Restrict identity documents and investor information to authorised people. Store the request and response securely with the relevant compliance file.
If a request is contested or unusually broad, seek legal or regulatory advice promptly. Accurate due diligence and appropriate confidentiality controls should be managed together.
Does a non-public register mean no bank can ask about members?
No. Assess the specific request and applicable basis.
Related fund and company resources
Read our VCC launch checklist, filing calendar reconciliation and financial authority records guide.
Get help with VCC administration
For VCC setup coordination, corporate records and accounting support, email [email protected] or WhatsApp +65 8501 7133. Tax advisers can assist with fund tax questions, and legal advisers from associated law firms can assist with fund documents, regulatory questions and disputes.