
Based on Chinese folkore, the 4th day of the Chinese Lunar New Year is an auspicious day as it is believed that the God of Fortune will visit earth.
Coincidentally, the 4th day of CNY 2020 on 28 January is when the PS Act came into force. (Well, companies commencing their payment services business might just be blessed with prosperity by the God of Fortune.)
On a more serious note, leading up to 28 January, Ingenia has been busy preparing clients. We are assisting various payment services providers, for example providing remittance and cryptocurrency services, in the upgrading of their frameworks and their licensing applications.
Contact us if you would like to discuss how we can facilitate your application.
Variable Capital Companies
MAS and ACRA have officially announced the launch of the Variable Capital Company Structure on 15 Jan 2020. The new structure offers fund managers greater operational flexibility and can be used for a wide range of investment funds.
Through the MAS VCC Pilot Programme, 20 investment funds have been launched as VCCs.
The MAS has also introduced a VCC Grant Scheme to help defray the cost. Co-funding of up to 70% of eligible expenses capping at SGD150,000 is available. More information on the launch of the VCC and the VCC Grant Scheme can be found here.
MAS Regulatory Requirements
2020 Deliverables Due Dates
Although still a couple of months away, in a blink of an eye, you will realise that the deliverables due are just around the corner.
As of now, the following are two upcoming MAS regulatory compliance due dates to bear in mind:
- Due 8 July 2020: To recapitulate, FIs have till 8 July 2020 to ensure the necessary opt-in confirmations are obtained from their customers (i.e. those onboarded before the ‘new’ AI regime kick-started at the beginning of 2019) who wish to be treated as accredited investors (AI) or opt-out confirmations if they do not wish to be treated as AIs. As such, it is prudent for FIs who have not yet received from their AIs all the opt-in or as appropriate, opt-out confirmations, to do so by or before 8 July 2020. Please feel free to reach out to us in case you require our support.
- Due 20 August 2020: Implementation of cyber hygiene requirements. On 6 August 2019, MAS issued notices on cyber hygiene. It made certain technology risk management measures mentioned in the Technology Risk Management Guideline mandatory. The mandatory measures include the following:
b. administrative accounts must be secured;
c. security patches must be implemented timely;
d. security devices to restrict unauthorised network traffic must be deployed;
e. malware protection measures must be implemented;
f. multi-factor authentication must be implemented for administrative accounts of critical
systems and accounts used to access customer information through the internet.
– Notice CMG-N03 Cyber Hygiene for capital markets entities.
– Notice PSN06 Cyber Hygiene for designated payment systems licensees and operators.

Industry Updates & Developments
Wealth Creation – Asia to Watch!
‘Asia is the region to watch when it comes to wealth creation over the next few years […]’ the Economist Intelligence Unit that produced the RBC Wealth Management’s 2019 Wealth Opportunity Index commented.
Singapore came in third, behind Mainland China (2nd) and the USA (1st) as a wealth opportunity hotspot. India and Hong Kong took the 4th and 5th place respectively.
The Index examines the drivers of wealth creation in 15 countries spread across regions which included the US, Western Europe and Asia Pacific. Economic fundamentals, market dynamics, innovation and risk were the four pillars used in the ranking.
Click here to read the full story.
What Wealth Managers are Avoiding in 2020?
Five wealth managers were interviewed to pick their thoughts on what assets to avoid in 2020.
As follows are their views:
1. Tsao Family Office – “At the moment, we are cautious about funds with meaningful exposures to lower quality credit assets. This is both for high yield bonds as well as leveraged loans.”
2. DBS Private Bank – “We generally avoid funds that may appear to have done very well, but were actually beneficiaries of luck more than skill.”
3. UOB Private Bank – “Sectors that we don’t like as much would be defensive ones that are very tied to the interest rate cycles, like utilities and telcos.”
4. Global Family Office – “We believe it’s time to avoid purely large cap funds, as any sell-off may be pronounced in this space due to stretched valuations.”
5. VP Bank – “Within the actual market environment, technology and large caps are overowned and overvalued. We prefer a more balanced risk-reward.”
Views on preferred assets were also shared briefly. Click here for full story.
What good has the Hong Kong unrest brought to Singapore, if any?
Apparently, signs are showing the trend of Hong Kong firms, even residents, looking to uprooting from Hong Kong and find greener pasture in Singapore. Examples include the shifting of a private equity event to Singapore, Hong Kong parents look out for Singapore schools, and family office advisers getting calls from clients wanting to move.
In the asset management sector, professional services firms shared that they have seen a surge in inquiries as well as a rise in applications from Hong Kong asset managers to open offices in Singapore and apply licenses to do regulated businesses.
Click here for full story or contact us for information on licensing requirements in Singapore.