Comment Letter to Monetary Authority of Singapore response to MASs Consultation Paper on Proposed Changes to the Regulatory Regime for Fund Management Companies and Exempt Financial Intermediaries

MFA submitted a letter to the Monetary Authority of Singapore (MAS) on June 3, 2010 in response to MASs Consultation Paper on proposed changes to the regulatory regime for fund management companies and exempt financial intermediaries. In our letter, we support MASs efforts to foster long-term growth of the fund management industry in Singapore. In addition, in our letter, we seek clarification and make recommendations on: (i) the application of the proposals to U.S.-based investment advisers that have a Singapore office or affiliate, where such office/affiliate confines its activities in Singapore to conducting research, providing analyses or providing related back office services; (ii) the proposed computation of assets under management; (iii) the requirement to employ two (2) full-time individuals with at least five (5) years of relevant experience who reside in Singapore; (iv) the imposition of risk-based capital requirements; and (v) the prohibitions on trade execution without compliance with certain requirements.