Singapore VCC insights
MAS 2025 VCC Governance Circular: Practical Checklist for Fund Managers
MAS published Circular IID 04/2025 on 26 June 2025 following its 2024 thematic review of VCCs and their managers. The circular sets out supervisory expectations and good practices for governance and management.
The practical question for a board is whether the fund’s records show how it is managed. A file of appointments and policies is only a starting point. The working checklist below is an implementation aid, not a substitute for reading the circular’s detailed requirements.
Compare the mandate with actual decisions
Take a recent investment decision and trace who proposed, assessed, approved and executed it. Compare that sequence with the management agreement and delegated authorities. Investigate any mismatch, including an informal sponsor instruction that bypasses the agreed process.
Review what reaches the board
Check whether reports explain material holdings, valuations, liquidity, conflicts and unresolved exceptions. Minutes should show the questions considered and decisions made. Where information was missing, record who will provide it and by when.
Test provider oversight
Select one cash or asset reconciliation and one investor-onboarding exception. Confirm who performed the work, who reviewed it and how an unresolved issue was escalated. Check access to supporting records rather than accepting a broad assurance that the provider handles compliance.
Address a quiet or inactive fund
If the strategy has not launched or investment activity has stopped, assess the continuing obligations and the commercial reason for retaining the structure. Put unresolved operational or filing matters before the board. Inactivity should not mean that nobody owns the next action.
Record and close gaps
Use an action list with the issue, responsible person, target date and evidence needed for closure. Return significant items to the board until resolved.
Read the official MAS circular and related guidance. Have the manager’s compliance team map the actual circular to the VCC’s procedures, including any requirements beyond the examples above.
