Independent Singapore VCC guidance
Direct answer
Preserve the communications that explain who proposed, challenged, approved, changed and released each material VCC investment decision. Give the event one identifier and link the approved thesis, mandate checks, conflicts, committee record, order instruction, amendments, execution evidence, settlement and final accounting. Capture approved channels automatically where possible, require prompt transfer of permitted exceptional messages, and prohibit rewriting the original record. Test retrieval by selecting a booked position and reconstructing the decision without relying on the people who made it.
At a glance
- Capture decision substance and authority, not every message without context.
- Use one event identifier from proposal through final books and investor reporting.
- Bring permitted exceptional communications into the controlled record promptly.
- Test retrieval from a booked position back to the original decision and challenge.
Who this is for
- Fund managers preserving investment, risk, committee and order communications for VCC mandates across approved business channels.
Important exclusions
- A universal retention period or legal-hold instruction without reviewing the manager permissions, instruments, policies and current obligations.
Define the event before collecting messages
Begin with the investment event, not the mailbox. Record the VCC, sub-fund or mandate, instrument, strategy question, proposer, decision owner, relevant reviewers, decision time and the identifier that will follow any order. Then define the communication population likely to contain decision substance: research notes, committee papers, chats, email, calls, meeting notes, system comments, risk challenge and provider instructions. This keeps the record focused enough to use while preventing a polished approval memo from hiding contradictory or later instructions.
Sources: Monetary Authority of Singapore · Monetary Authority of Singapore · Monetary Authority of Singapore| Stage | Record to preserve | Reconstruction test |
|---|---|---|
| Research | Source material, analysis and unresolved limitations | Can a reviewer see what information supported the proposal? |
| Challenge | Risk, compliance, valuation and conflict questions | Were objections answered, conditioned or left open? |
| Approval | Decision, authority, scope and expiry conditions | Who could approve and what exactly was authorised? |
| Instruction | Order details, route, allocation and changes | Does the instruction remain within the approved decision? |
| Outcome | Execution, settlement, booking and monitoring | Did the books receive the result that was actually approved? |
Related guidance: substantive VCC management evidence file
Set channel rules people can actually follow
List approved communication tools by activity and explain what each may be used for. A research discussion, formal committee decision, time-sensitive order instruction and provider escalation may need different controls. Where the business permits a mobile or collaboration channel, define capture, export and linking expectations before use. If a channel cannot preserve the required record, it should not carry a material instruction. Emergency arrangements need a controlled route back into the main repository, an owner and a time-bound reconciliation rather than an open exception for convenience.
Sources: Monetary Authority of Singapore · Monetary Authority of Singapore · Monetary Authority of SingaporePractical channel-control questions
- Can the channel identify participants, time, edits, attachments and the complete conversation context?
- Can records be searched and exported without depending on one employee device?
- Does the channel prevent or reveal deletion, backdating and silent replacement of material instructions?
- Can the message link to the mandate, instrument, approval and order identifier?
- Is there a tested route for emergencies, personal-device discovery and later reconciliation?
Link research, challenge and final authority
Preserve enough of the analysis to show why the proposed investment fit the actual mandate, how material risks were assessed and which assumptions remained uncertain. The record should distinguish information available at the decision time from later knowledge. Risk and compliance challenge must remain visible even when the proposal is approved. If approval is conditional, translate each condition into a field or hold that operations can test. A vague statement such as approved subject to checks is not executable unless the checks, owner and evidence are named.
Sources: Monetary Authority of Singapore · Monetary Authority of SingaporeCommittee minutes should record decision substance without becoming a transcript. Capture attendees, conflicts, documents considered, key challenge, alternatives, conditions, abstentions, outcome and next review trigger. Link any discussion that occurred outside the meeting and materially changed the decision. Where authority was delegated, preserve the effective delegation and its limits. This allows the VCC board and manager oversight functions to understand the process without recreating portfolio management or relying on a single senior person memory.
Sources: Monetary Authority of Singapore · Monetary Authority of Singapore · Accounting and Corporate Regulatory AuthorityRelated guidance: VCC investment due-diligence challenge
Carry the identifier into the order trail
The approved decision should become an order through a controlled translation. Record instrument identifiers, side, quantity or sizing method, portfolio, allocation intent, price or execution constraints, counterparty route, validity and applicable approvals. Link amendments and cancellations as new events rather than overwriting the original instruction. If the portfolio manager and trader discuss a material change, capture both the reason and authority. Operations should be able to compare the final execution with the version that was active at that time.
Sources: Monetary Authority of Singapore · Monetary Authority of SingaporeInstruction lineage
- ReleaseConvert approved conditions into a complete instruction with a unique event and order reference.
- ChangeRecord amendments, cancellations and rerouting with the person, time, reason and authority preserved.
- ExecuteLink venue, broker, fills, cost information and exceptions to the instruction active at execution.
- BookReconcile settlement, position, cash, fee and accounting records to the executed result.
Related guidance: VCC trade amendment and cancellation review
Preserve exceptions without contaminating the file
When a relevant message appears on an unapproved channel, do not ask the sender to recreate it from memory and delete the original. Preserve the available evidence, restrict access if it contains sensitive information, record how it was discovered and link an authenticated copy to the event. Assess whether the instruction was acted on, whether the decision or order record is incomplete and whether broader channel use needs investigation. Correct the process while keeping the exception visible. A later summary can explain the event, but it should not replace the original evidence.
Sources: Monetary Authority of Singapore · Monetary Authority of Singapore · Monetary Authority of SingaporeException response
- No material contentRecord the review result and reinforce the channel rule without enlarging the event unnecessarily.
- Decision content foundPreserve and link the message, assess authority and reconcile it to the approved decision record.
- Instruction acted onTrace execution and booking, open an incident or correction route and protect the original chronology.
- Pattern or concealment concernEscalate independently, broaden the preservation scope and consider conduct, legal and regulatory consequences.
Test retrieval from the final books
Select a position, cash movement or performance contribution from the final books and reconstruct the event backwards. The reviewer should find the execution and settlement, active instruction, approval, challenge, analysis, conflicts and source records without asking the original decision-maker where files were saved. Repeat with a rejected proposal, amended order and exceptional channel. Record missing links, duplicate versions, inaccessible provider data and timestamps that cannot be reconciled. Remediation should address the source process, not merely assemble a one-off pack for the sample.
Sources: Monetary Authority of Singapore · Monetary Authority of Singapore · Monetary Authority of SingaporeRelated guidance: VCC compliance record retrieval drill
Frequently asked questions
Should every investment message be stored forever?
This guide does not set a universal period. The manager should apply current legal, regulatory, contractual, litigation, privacy and policy requirements to each record class. The practical control is to classify records clearly and stop ad hoc deletion from determining what survives.
Can committee minutes replace chat and email records?
Minutes can summarise the decision, but they should not erase material instructions, conflicts, challenge or changes communicated elsewhere. Link the underlying record when it is needed to reconstruct authority, timing or the reason the decision changed.
What if an urgent instruction arrives on a personal device?
Follow the approved exception route: preserve the original, transfer an authenticated copy into the controlled repository, link it to the event, assess whether it was authorised and acted on, and investigate repeated or deliberate use.
Who should run the retrieval test?
Use a reviewer independent of the original decision and record assembly. Operations, compliance, risk or internal assurance can perform the test if they have appropriate access and do not rely on the people being tested to fill missing links.
Does a complete order ticket prove the investment decision?
No. It proves parts of the instruction and execution trail. A complete decision record also shows mandate fit, analysis, material challenge, conflicts, approval authority, conditions, amendments and how the final position reached the books.
Official sources and further reading
- Risk Management Practices for Fund Management Companies (Monetary Authority of Singapore)
- Guideline on Licensing and Conduct of Business for Fund Managers (Monetary Authority of Singapore)
- Guidelines on Individual Accountability and Conduct (Monetary Authority of Singapore)
- Technology Risk Management Guidelines (Monetary Authority of Singapore)
- Legal Obligations of a VCC Director (Accounting and Corporate Regulatory Authority)
Discuss a Singapore VCC structure
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General information only. This article is not legal, tax, regulatory or investment advice and does not imply affiliation with or endorsement by ACRA, MAS or IRAS.