For a long time, Singapore has had a reputation of being a fairly easy place to set up a hedge fund in Asia. If a hedge-fund manager didn't want to jump through all the regulatory hoops imposed in Hong Kong, the Lion City represented a benign alternative location. That may be set to change.
Among the new measures that are understood to be possibilities within an enhanced regulatory regime in Singapore, there may be new categories titled 'retail fund managers' and 'institutional/accredited investor fund managers'.
If you're a hedge fund manager, you'd logically assume that the latter is probably the one for you.
If a fund doesn't have a dedicated compliance officer, the manager is restricted to 30 accredited/institutional investors (for segregated-account mandates) or 100 accredited/institutional investors (for fund offerings).
Within this category, a fund manager would have to have a minimum of two directors, one of whom must be an executive director and living in Singapore. Nominee directors such as lawyers and corporate secretaries would not be allowed.
There may also be a minimum requirement of two licensed representatives for such funds. Written examinations are not expected (which is good, because that would be such a drag), but each representative would need a minimum of five years' relevant experience. Funds that start with only one key individual would therefore fall foul of this requirement.
"The changes in Singapore potentially close off the city as the easier option for start-ups and locating Asian satellite offices," says Rolfe Hayden, a partner at law firm Simmons & Simmons in Hong Kong. "Noticeably fewer clients are giving Singapore serious consideration -- if you must be regulated, absent some other important factor, Hong Kong is likely to be the first choice."
The FAQ section on the Monetary Authority of Singapore's website was amended in January, and while the update doesn't go all the way, it gives some idea about the direction that regulation is moving in.