Private banking onboarding for newly licensed CMS holders — Costs and fees breakdown
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
Private banking onboarding for a newly licensed Capital Markets Services (CMS) holder is the process of opening operating and client-money accounts, satisfying the bank’s due diligence, and evidencing the firm’s regulatory standing before it can transact. It runs in parallel with, but separately from, the Monetary Authority of Singapore licensing itself, and typically takes several weeks once the licence is granted. This guide to private banking onboarding for newly licensed CMS holders sets out who it is for, the costs and fees in Singapore dollars, the step-by-step process, and the common mistakes to avoid.
What private banking onboarding involves
A CMS licence, granted under the Securities and Futures Act 2001, authorises a firm to conduct regulated activities such as fund management or dealing in capital markets products. Section 82 of the Securities and Futures Act 2001 establishes the requirement to hold a licence for regulated activities, and section 86 governs the grant of a licence by the Monetary Authority of Singapore.
Holding the licence is only the first step. To operate, the firm must open banking relationships: an operating account for its own funds and, where it holds client assets, segregated client-money accounts that satisfy the regulator’s customer asset protection rules. Private banks apply their own onboarding due diligence on top of the regulatory position. For a related perspective, see our guide on VCC Act 2018 — Section 32-33 distribution out of capital — Step-by-step walkthrough.
Who this applies to
This applies to newly licensed fund managers, including registered fund management companies and licensed fund management companies, corporate finance advisers, and dealers who need custody and settlement infrastructure. It also applies to family offices that have taken a CMS licence rather than relying on an exemption.
The firm’s directors and substantial shareholders will be assessed for fitness and propriety by both the regulator and the bank, so the same individuals should expect to provide overlapping documentation. See also our detailed walkthrough on MAS Payment Services Act licensing — MPI and SPI — Costs and fees breakdown.
Eligibility and documentation the bank will require
Banks will ask for the CMS licence and the firm’s regulatory permissions, certified incorporation documents, the register of directors and shareholders, board resolutions authorising account opening, and detailed know-your-customer information on beneficial owners. For client-money accounts, the bank will want to see the firm’s customer asset arrangements.
Source-of-wealth and source-of-funds evidence is central. A newly licensed manager should prepare a clear narrative of the firm’s capital, its strategy, expected transaction flows and target investor base, because onboarding teams assess this against money-laundering risk. Authoritative guidance is published by www.mas.gov.sg.
Cost and timeline breakdown
Private banks do not usually charge a fee to open an operating account, but they may impose minimum balances, custody fees and transaction charges. The real cost is time and the professional support needed to compile a clean onboarding pack.
From a complete submission, expect roughly four to eight weeks for a private bank to complete onboarding for a regulated firm, longer where beneficial ownership is complex or spans several jurisdictions. Aligning the bank timeline with the licence grant avoids a gap where the firm is licensed but cannot yet transact.
Step-by-step onboarding process
First, confirm the CMS licence conditions and the regulated activities permitted. Second, select a private bank whose custody and product coverage match the strategy. Third, prepare the corporate and regulatory pack, including board resolutions and authorised signatory lists. Fourth, submit know-your-customer and source-of-wealth documentation for all controllers. Fifth, complete the bank’s risk assessment and answer follow-up queries. Finally, set up client-money segregation and reconciliation processes before the first client transaction.
Common mistakes and gotchas
The most common delay is an incomplete beneficial ownership picture, especially where trusts or holding companies sit above the licensed entity. Another is failing to distinguish the operating account from client-money accounts, which triggers customer asset protection obligations.
Firms also underestimate how much the bank’s onboarding differs from the regulator’s assessment; passing the licensing bar does not guarantee frictionless banking. Starting the bank conversation early, and keeping the regulatory narrative consistent across both processes, is the practical fix.
Private banking onboarding for newly licensed CMS holders: costs and fees at a glance
| Item | Indicative amount | Notes |
|---|---|---|
| Private bank operating account opening | S$0 | banks rarely charge, but minimum balances apply |
| Custody / safekeeping fees | 0.05% – 0.30% p.a. | of assets under custody, bank-dependent |
| Onboarding documentation support (adviser) | S$3,000 – S$10,000 | indicative, for a clean regulated-entity pack |
| Client-money account set-up and controls | S$2,000 – S$8,000 | process design and reconciliation set-up |
Figures are indicative for 2026 and vary with scope and provider. Confirm current fees before relying on them.
Related guides
- VCC Act 2018 — Section 32-33 distribution out of capital — Step-by-step walkthrough
- Reducing Share Capital in Singapore: A Director’s Guide (2026)
- MAS Payment Services Act licensing — MPI and SPI — Costs and fees breakdown
FAQs
Can I bank before my CMS licence is granted?
You can open a basic corporate account, but private banks will not complete onboarding for regulated activity or client-money handling until the CMS licence and its conditions are confirmed.
How long does private bank onboarding take?
Typically four to eight weeks from a complete submission, longer where beneficial ownership spans multiple jurisdictions.
Do I need segregated client accounts?
If the firm holds client assets or moneys, customer asset protection rules require appropriate segregation. Own-account trading of a proprietary firm may not, depending on permissions.
Is this financial or legal advice?
No. This is general information about onboarding steps. Licensing and customer asset arrangements should be confirmed with qualified professionals.
Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email [email protected]. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.