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An SFA 04-G08 scope test records the manager, scheme, redemption features and evidence behind each fund classification.
An SFA 04-G08 scope test should classify every fund and sub-fund using its manager, legal form, investor offer, redemption features and governing documents. A label such as private fund, closed-ended strategy or VCC is not enough to settle the result.
The output is a controlled inventory with reasons and evidence. It allows risk, compliance, operations and the board to apply the revised liquidity work to the right products.
Identify the manager first
Start with the legal entity performing fund management and its regulatory status. Record the capital markets services licence details, exemptions relied on and any delegated portfolio-management arrangement.
The MAS SFA 04-G08 page states that the guidelines apply to licensed fund management companies and concern liquidity risk in collective investment schemes. Keep the current guideline text with the review rather than relying on an older summary.
If a group has several managers, do not classify products at brand level. Link each scheme to the entity that makes or delegates the relevant management decisions.
Determine whether the arrangement is a scheme
Describe the legal arrangement, pooling, investor rights and management of contributions. Use the definitions and applicable provisions in the Securities and Futures Act 2001 with advice where the structure is unclear.
Record whether the product is a company, VCC sub-fund, limited partnership, unit trust or another vehicle. The vehicle matters, but the economic arrangement and legal rights still need review.
Keep the constitution, limited partnership agreement, trust deed, subscription documents and offering material that support the conclusion. Where an exclusion or exemption is relied on, cite the exact provision and facts.
Read the redemption terms as they operate
State whether investors have a right to redeem, how often they can submit requests, the notice period, settlement period and any lock-up. Record limits, deferrals, side pockets, redemption restrictions, suspension powers and board discretion.
A fund called closed-ended may still have contractual liquidity, periodic repurchase arrangements or side-letter rights that need analysis. An open-ended label also does not describe every restriction or cost borne on exit.
Compare the offering terms with administrator procedures and investor records. A classification based only on the prospectus can miss a side letter or an operational practice.
Classify asset and liability features
Record the main assets, dealing markets, settlement cycles, concentration, valuation frequency and restrictions on transfer. Add borrowing, derivatives, margin, collateral and other predictable cash demands.
The scope record does not replace the liquidity assessment. It gives that assessment a reliable starting point by identifying products where redemption promises and cash demands can interact with less liquid assets.
Flag feeder funds, master funds and parallel vehicles. The investor may redeem from one layer while liquidity depends on another.
Check the investor and offer position
Record whether the scheme is authorised, recognised, restricted or offered under another route. State the investor population and jurisdiction of offer. Keep the current registration or notification evidence.
Do not assume that a professional-investor product has no liquidity risk or governance duty. The legal and supervisory treatment may differ, but the manager still needs a reasoned classification.
Where Singapore and foreign rules overlap, record which adviser owns each conclusion. Avoid combining two jurisdictions into one unsupported answer.
Resolve products with mixed features
Mixed structures need a short legal and operating note. Examples include a closed-ended vehicle with withdrawal rights, a long lock-up followed by periodic redemption, an exchange-traded interest, or separate share classes with different liquidity.
Classify at the level where rights differ. One umbrella answer may be wrong when sub-funds or classes have distinct terms.
Use an interim conservative treatment while a material uncertainty is unresolved. Assign an owner and decision date rather than leaving the product outside the implementation work by default.
Connect classification to implementation
The May 2026 MAS information paper on risk-management practices emphasises effective governance, current policies, challenge and retained evidence. Apply the same discipline to scope decisions.
For each in-scope product, name the next review: asset-liability alignment, redemption-cost method, liquidity-management tools, stress testing, disclosure or event reporting. For each out-of-scope product, set a trigger for reconsideration.
Triggers may include a change to redemption terms, new share class, manager, offer route, investor side letter, asset strategy or leverage.
Link every scope conclusion to the version of the guideline and product documents reviewed. If MAS guidance or the fund terms change, the inventory should identify the affected products without repeating the entire classification exercise from memory.
Include outsourced functions in the review. An administrator, transfer agent or foreign delegate may hold facts needed to understand dealing rights and cash demands, but the manager should retain the classification and escalation record.
Use an SFA 04-G08 scope table
| Question | Evidence | Owner |
|---|---|---|
| Who manages? | Licence and delegation records | Compliance |
| What is the arrangement? | Constitutive documents | Legal |
| Can investors redeem? | Terms and side letters | Operations |
| What creates cash demand? | Assets and liabilities | Risk |
| How is it offered? | Offer and investor records | Compliance |
| What changes the result? | Review triggers | Product owner |
Approve and maintain the record
Have legal, compliance, risk and operations confirm the facts they own. Record any disagreement and the final basis. The board or authorised committee should receive the inventory and material exceptions.
Review the scope record at least when a fund launches, changes terms, adds a class or experiences a liquidity event. Preserve earlier versions so a reviewer can see when the classification changed.
The MAS liquidity-guideline implementation record covers the next operating work. The Singapore VCC launch-readiness guide is the pillar cornerstone.
A defensible SFA 04-G08 scope test prevents both missed obligations and indiscriminate controls. The Funds and VCC Structures hub connects the wider fund library.