Singapore VCC insights
VCC for Single Family Offices After MAS Governance Scrutiny
A family considering a VCC should be able to explain what the fund manager will actually do. A structure in which the manager appears only on the paperwork is difficult to reconcile with a credible fund-management arrangement.
MAS’s June 2025 governance circular followed a thematic review of VCCs and their managers. It is a useful reason for families to examine how their proposed arrangement will work in practice, rather than focus only on incorporation and tax paperwork.
Separate family wishes from investment authority
The family can set objectives and constraints. The documents should then explain who has authority to select investments, approve transactions and manage risk. If a family member has an investment role, have advisers assess that person’s regulatory position and document the role accurately.
An informal understanding that overrides the signed mandate creates uncertainty for the board and providers.
Give the board something useful to review
Reports should cover holdings, significant transactions, valuations, liquidity, conflicts and exceptions. Minutes should record decisions and the reasons for them. Repeatedly noting that everything is satisfactory is not a substitute for examining the portfolio.
Plan for disagreement
What happens if the family wants an investment outside the mandate, a related-party transaction or a withdrawal the portfolio cannot support? Agree an escalation route before the issue arises. The manager should not have to choose between an undocumented instruction and an unsuitable transaction.
Revisit the case for the VCC
If there is no genuine investment-management purpose, compare other structures. The costs and obligations of a fund should serve the family’s needs. Our family-office suitability guide is a starting point, followed by advice on the actual assets and decision-makers.
