On 29 May 2026, the Monetary Authority of Singapore published two companion information papers, one on risk management practices and one on valuation practices, addressed to fund management companies operating in Singapore. Both papers were drawn from thematic inspections that MAS carried out across a range of investment strategies, including reviews conducted by external auditors appointed on MAS’s behalf. Taken together, they set out, in unusually specific terms, what MAS expects to see documented at the board and senior management level of a licensed fund manager.

Most of the commentary on these papers so far has focused on Variable Capital Companies and how the guidance touches sub-fund level segregation of duties. That is a real and useful angle, and readers looking specifically at VCC sub-fund mechanics should look there. This article takes a different, and for most of our clients more relevant, angle: what the twin papers mean for licensed fund management companies generally, and in particular for the growing population of Section 13O and Section 13U single family offices that hold a Capital Markets Services licence exemption rather than a full licence.

For family office principals, this is not an academic compliance update. The exemption that lets a single family office manage its own family’s money without a CMS licence has always come with standing conditions. MAS’s twin papers are the clearest signal yet that the substance behind those conditions, proper governance, real board oversight and a paper trail that can survive scrutiny, is where supervisory attention is heading next.

What the 29 May 2026 Information Papers Actually Cover

Before going further, it is worth being precise about what MAS has actually published, because the two papers are guidance rather than new legislation. They do not create new statutory obligations under the Securities and Futures Act 2001. Instead, they describe MAS’s supervisory expectations of what good governance, policies and controls look like in practice, benchmarked against findings from actual inspections, and published as the Information Paper on Risk Management Practices for Fund Management Companies and the Information Paper on Valuation Practices for Fund Management Companies. MAS has said plainly that fund management companies are expected to benchmark their current practices against the papers and remediate any gaps promptly. In supervisory language, that is as close to a mandate as guidance gets.

Risk Management Practices for Fund Management Companies

The risk management paper is organised around five areas that any fund manager’s board should recognise as the full life cycle of an investment decision:

  • Governance: the board and senior management must establish governance structures, policies and controls over fund launches, investment changes, due diligence and ongoing monitoring, with oversight coming from committees that are independent of the portfolio management function. Conflicts of interest must be identified, mitigated and disclosed, not simply noted and left unaddressed.
  • Policies and procedures: comprehensive policies must exist before a fund is launched, with clearly assigned roles, a regular review cycle, and documented justification whenever the firm deviates from its own stated policy.
  • New fund launches and changes to existing funds: before launching or materially changing a fund, the manager must assess the investment objectives, risk-return profile, operational readiness, personnel suitability and regulatory requirements, with proper approvals and due diligence on the underlying investment model.
  • Investment due diligence: sufficient due diligence is expected on every prospective investment, covering authenticity, suitability and risk-return assessment. Critically, MAS makes clear that a fund manager remains accountable for this even when it relies on external advisers or introducers.
  • Ongoing monitoring: independent monitoring frameworks must cover material risks, including market, credit, counterparty, liquidity and operational risk, with defined metrics, limits and timely escalation when a limit is breached. Disclosures to investors must accurately reflect actual exposures, not a stale or idealised picture.

Valuation Practices for Fund Management Companies

The companion paper on valuation sets a parallel standard for how a fund’s assets are priced:

  • Governance: the board and senior management must ensure independence and objectivity in valuation, in both normal and stressed market conditions, again with oversight from committees independent of portfolio management.
  • Policies and procedures: valuation policies must cover every asset class and instrument the fund holds, with defined methodologies, a set valuation frequency, escalation procedures for disputed prices, and a regular review cycle.
  • Price validation checks: independent checks such as price variance testing, source-to-source comparison, stale price detection and net asset value variance analysis must be built in, with defined tolerance levels and a clear escalation path when a check fails.
  • Valuation approaches: valuations must be performed by competent, independent parties, applying the familiar three-level fair value hierarchy: quoted prices, observable inputs, and unobservable inputs. MAS specifically flags heightened complexity around private credit and digital asset holdings, and expects fair value decisions to be communicated promptly to the fund administrator so that reported net asset values are never out of step with the manager’s own internal view.

Why This Is Not Just a VCC Sub-Fund Story

It is easy to read these papers narrowly as a Variable Capital Company issue, because VCCs with multiple sub-funds do raise particular questions about ring-fencing and cross-sub-fund conflicts. But the two information papers are addressed to fund management companies as a category, not to any single fund structure. A licensed fund manager running a single Pte Ltd fund, a Section 13O family office fund, or a Section 13U umbrella structure is squarely within scope, whether or not a VCC is anywhere in the picture.

That distinction matters for how a family office should read this guidance. The governance and documentation expectations sit at the level of the manager, its board, its investment committee and its policies and procedures manual, not at the level of the fund vehicle’s legal wrapper. A family office that has never touched a VCC and never plans to still needs to be able to show a regulator, or its own auditor, that its investment process is governed the way MAS now says a well-run fund manager’s process should be governed.

Section 13O and 13U Single Family Offices: The Governance Angle

Licensing Exemption Is Not a Governance Exemption

A single family office structure typically relies on the related corporation exemption or the exemption under the Securities and Futures Act for a person managing funds solely for related corporations or family members, so that it can carry out fund management activity without holding a full Capital Markets Services licence. Many principals, understandably, treat that exemption as meaning the whole licensing framework does not apply to them. It is a reasonable assumption, and it is wrong in the way that matters here.

The exemption removes the need for a licence. It does not remove MAS’s expectation that the entity carrying on fund management business is run properly. Both the Section 13O and Section 13U tax incentive schemes, which most single family offices rely on for their income tax exemption, are themselves conditional on the fund being managed by a Singapore-based manager that meets ongoing conditions on staffing, local business spending and, implicitly, on the quality of how that manager operates. Our earlier comparison of the Section 13O and 13U tax incentives sets out those standing conditions in detail, and it is worth re-reading them now with the risk management and valuation papers in mind. Every one of the five investment process stages in the risk management paper, and every one of the valuation controls in the companion paper, is exactly the kind of substance MAS looks for when it reviews whether a family office genuinely meets the spirit of its award conditions, not merely the letter of a headcount or spending threshold.

What Changes for Boards and Investment Committees

For a licensed fund management company, most of what the two papers describe should already exist in some form, since it has long been implicit in MAS’s supervisory approach to CMS licence holders. For a single family office, the gap is often wider, because many were set up quickly around a family’s existing wealth management relationships, with a light board and an informal investment process built around the principal’s own judgement.

That informality is precisely what the twin papers put under a brighter light. A family office board, even a small one comprising the principal, a family member and an independent director, is now expected to be able to point to a documented governance structure that separates who decides to invest from who checks that the decision was diligenced properly. Where a single family office also manages a modest portfolio of less liquid assets, private credit positions or a stake in a family business, the valuation paper’s warning about heightened complexity in Level 3 assets is directly on point, and boards should expect their auditors and MAS to ask harder questions about how those valuations are arrived at and reviewed.

Documentation and Governance Practices to Put in Place Now

Based on the two papers, a practical starting checklist for a licensed fund management company or a Section 13O or 13U family office looks like this:

  • A written investment policies and procedures manual, approved by the board, covering fund launch, ongoing investment decisions, due diligence and monitoring, reviewed at least annually.
  • A documented conflicts of interest register, identifying where the principal, family members or related parties sit on both sides of a transaction, with mitigation steps recorded, not just disclosed after the fact.
  • Board or investment committee minutes that show independent oversight of portfolio decisions, distinct from the person or team executing the investment.
  • A pre-investment due diligence checklist covering authenticity of the counterparty, suitability against the fund’s stated strategy, and a documented risk-return assessment, retained on file for each investment made.
  • A valuation policy naming the methodology for each asset class held, the valuation frequency, who performs the valuation, and the escalation path if a price cannot be validated.
  • Independent price validation checks appropriate to the portfolio, even in simplified form for a smaller family office, covering stale pricing and material variance from the last reported value.
  • A monitoring log recording material risk metrics against pre-set limits, with a record of any breach and how it was escalated and resolved.
  • Clear allocation of these responsibilities among the principal, any investment professionals, and the corporate secretary or external compliance support, so nothing depends on one person’s memory.

None of this needs to be built from scratch as an enterprise risk framework more suited to a large licensed manager. MAS itself acknowledges a risk-based and proportionate approach, scaled to the size and complexity of the business. For a small single family office, the same five governance themes can sit in a handful of concise documents rather than a lengthy manual, provided the substance, independent oversight and a genuine paper trail, is actually there.

Practical Next Steps for Principals and Corporate Secretaries

For principals reviewing their own structure, and for the corporate secretaries and compliance support working alongside them, a sensible sequence over the next few months looks like this:

  1. Pull the family office’s current award conditions and licensing exemption basis, and check them side by side against the governance and documentation points above.
  2. Where the family office sits within a broader estate or multi-entity structure, confirm which board actually holds oversight of the investment process, and make sure that board’s minutes reflect real, substantive review rather than a rubber stamp. Our comparison of single versus multi-family office structures is a useful reference point if governance responsibilities are currently spread thinly across a small team.
  3. Document the valuation methodology for every illiquid or hard-to-price holding now, before an auditor or MAS reviewer asks for it during an inspection or an annual award condition review.
  4. If the family’s fund vehicle is, or may become, a Variable Capital Company, note that sub-fund segregation and cross-sub-fund conflict management sit as a related but distinct governance layer on top of everything covered here; the choice between a VCC and other structures such as a Cayman SPC is covered separately in our VCC versus Cayman SPC comparison, and readers who want the specific VCC Act mechanics behind that choice can also refer to a dedicated resource at variablecapitalcompaniesact.com.
  5. For principals who are still finalising their own move to Singapore alongside setting up the family office, our guide to relocation pathways for high-net-worth individuals is a useful companion piece, since residency status and personal financial planning decisions often run in parallel with the family office’s own governance build-out.
  6. Revisit the family constitution or shareholders’ agreement underpinning the family office. Well-documented governance frameworks are not just a regulatory box to tick; they also reduce the risk of ordinary family disagreements over investment decisions escalating into full-blown disputes.
  7. Engage the corporate secretary early. Much of what MAS is now asking for, board minutes, registers, policy documents and version-controlled procedures, is exactly the discipline a competent corporate secretarial function already applies to statutory compliance, and extending that discipline to the investment process is a natural next step rather than a new function to build from zero.

Family offices that have not yet reviewed their broader structure against the current family office setup requirements should treat these twin papers as a prompt to do so, rather than waiting for the next award renewal cycle or the next MAS thematic inspection to raise the same questions from the other side of the table. Principals reworking their broader investment strategy at the same time may also find it worth revisiting the fundamentals of portfolio construction, a topic covered in general terms by independent resources such as littlebigreddot.com’s investment section.

Conclusion

MAS’s twin information papers of 29 May 2026 are guidance, not new law, but they read as a clear statement of intent: fund management companies, including the CMS-exempt single family offices operating under Section 13O and Section 13U, are expected to be able to demonstrate real governance, not just cite an exemption and move on. For most family offices, the underlying practices, sensible oversight, a documented investment process, defensible valuations, are not radically new. What has changed is the expectation that all of it is written down, owned by a named person or committee, and ready to be produced on request.

Getting ahead of that expectation now, while it is still framed as supervisory guidance rather than an enforcement finding, is considerably more comfortable than retrofitting a governance framework after an inspection letter arrives. A good corporate secretary, working alongside the family office’s own investment professionals, can put most of the documentation above in place within a single quarter.

To speak with the team at Raffles Corporate Services, you can email [email protected] or call, SMS, or WhatsApp +65 8501 7133. We are happy to assist with any queries.

The Editorial Team, Raffles Corporate Services