Raffles Consulting Services
The Hedge Fund Investment Programme has been announced but details are pending. Managers can prepare a factual Singapore readiness file now.
MAS has announced the Hedge Fund Investment Programme, but it has not opened an application route or published eligibility criteria. On 19 August 2026, the authority said it will invest with hedge fund managers committed to establishing or deepening their presence in Singapore. More details will follow when ready.
A manager can prepare now without claiming eligibility. Build a dated readiness file covering the firm, strategy, Singapore licensing position, local decision-making, investment team, service providers, risk controls and the additional presence the programme could support.
Record only what MAS has announced
The MAS asset management announcement describes three separate measures: the proposed profit-related returns tax exemption, the Hedge Fund Investment Programme and a ONE Pass Investment Management Track.
For the hedge fund programme, MAS states that it will invest with managers committed to establishing or deepening their Singapore presence. It also identifies broader aims, including anchoring global and regional managers, investment talent, ancillary service providers and prime brokerages.
MAS has not yet published the allocation size, fund terms, strategy preferences, minimum firm scale, application dates, selection method or reporting conditions. Put each unknown on a watchlist. Do not fill the gaps with terms from another MAS programme or a media report.
Define the manager and strategy accurately
Prepare a concise legal and operational profile of the applicant or relevant management entity. State its ownership, group structure, regulatory permissions, offices, assets under management, investors, track record period and senior decision-makers.
Describe the strategy in ordinary investment terms. Record asset classes, markets, liquidity, use of leverage, short exposure, derivatives, concentration, capacity and risk limits. Separate realised audited performance from estimates, back tests or a predecessor record.
If teams across several offices manage the strategy, show which decisions the Singapore team makes today and which decisions could move here. Make the organisational chart match the investment-management agreements, employment contracts and actual committee practice.
Confirm the regulatory perimeter
Fund management is a regulated activity under the Securities and Futures Act 2001. The readiness file should identify the relevant Capital Markets Services licence or exemption and the entity that conducts each regulated activity.
Use the current MAS Financial Institutions Directory to verify the public licence record. Keep a dated copy of the result, but do not treat a directory listing as evidence that every proposed product, investor or activity is permitted.
Record any licence variation, representative notification or approval that the proposed Singapore expansion may require. Where the perimeter is uncertain, obtain Singapore legal advice before describing the plan to investors or employees.
Explain what a deeper Singapore presence means
A credible file should state the change from the current position. This may involve investment professionals, portfolio authority, research, risk, operations, technology, investor relations or group leadership. It should not count people who will remain abroad or roles already required for another commitment as new programme value.
For every proposed role, include title, responsibility, seniority, location, expected hiring period and decision rights. Distinguish a transfer from a new local hire. Explain how the role connects to Singapore teams and professional development.
Premises, systems and providers also matter. Record which functions will use Singapore banks, prime brokers, administrators, auditors, legal advisers, data vendors and technology teams. The plan should follow the strategy’s real operating needs rather than add suppliers for appearance.
Prepare institutional due diligence material
Prepare Hedge Fund Investment Programme diligence
MAS will probably conduct careful diligence even though it has not published the final process. Organise audited financial statements, performance records, valuation policies, risk reports, compliance history, service-provider agreements, cybersecurity controls and key-person arrangements.
Reconcile performance across the administrator, prime broker and financial statements. Label gross and net returns, fees, expenses, leverage and any change in strategy. Explain material drawdowns and operational events without removing an unfavourable period.
List litigation, regulatory enquiries, breaches, investor disputes and material control failures, including how each matter was resolved. A complete exception log is more credible than a file that appears perfect because inconvenient records were excluded.
Use a readiness matrix
| Workstream | Evidence ready now | Pending programme detail |
|---|---|---|
| Manager status | Licence, ownership and management agreements | Eligible applicant entity |
| Strategy | Mandate, capacity, performance and risk record | Eligible strategies and terms |
| Singapore presence | Current roles and proposed additions | Required commitment and period |
| Operations | Provider map and control reports | Required local service use |
| Diligence | Financial, compliance and exception files | Submission format and review process |
Keep commercial planning conditional
Do not promise staff, investors or landlords that MAS will provide capital. Model the Singapore expansion with and without programme participation. Identify which hires and commitments the manager can support commercially under either case.
A board paper can approve preparation, official engagement and a conditional budget while reserving any final application or binding commitment. Record assumptions, decision dates and the person responsible for monitoring new MAS guidance.
Coordinate the programme watchlist with the proposed profit-related returns exemption and ONE Pass track, but keep the evidence and decisions separate. Qualification for one measure has not been stated as qualification for another.
Refresh the file when details arrive
Assign one owner to monitor MAS announcements and the relevant application channel. When MAS publishes terms, compare each actual criterion with the readiness matrix. Remove material that MAS does not request and add evidence for any new condition.
The Singapore VCC launch readiness guide is the pillar cornerstone. The profit-related returns tracker covers the separate proposed tax measure, while the fund-management licence comparison explains one structural choice. The Funds, VCCs and Cross-Border Structures hub connects the library.
The best readiness file is accurate enough to be shortened later. It shows what the manager already does in Singapore, what it is prepared to add and which important programme terms remain unknown.