Regulatory Alerts2018-01-05
Summary of Amendments to the Guidelines on Compliance Function for Fund Management Companies
The Securities Commission issued revised guidelines on 5 January 2018 to update the Compliance Function requirements for fund management companies. The amendments introduce definitions for cross trades and IMAs, clarify the utilization of soft commissions, and mandate that compliance officers verify cross trades. Additionally, the revision renumbers paragraphs and redrafts sections to enhance clarity on reporting submissions and consent disclosures.
Page 1 of 1 Summary of Amendments to the Guidelines on Compliance Function for Fund Management Companies (Compliance Guidelines) (Revised: 5 January 2018) The following table provides a summary of amendments made to the Guidelines on Compliance Function for Fund Management Companies revised on 5 January 2018: A. Specific amendments No Reference in the Compliance Guidelines Comments Prior to 5 January 2018 Revised version dated 5 January 2018
- Para. 2.01
Para. 2.01 cross trade IMA Inclusion of the definition of ‘cross trade’ and ‘IMA’. 2. Para. 4.04 (o) Para. 4.04 (p) Renumbering of existing paragraph and redrafting on submissions to be made to the SC where reference to specific reports to be made has been moved under the common reporting platform. 3. Para. 4.04 (p) Para. 4.04 (o) Renumbering of existing paragraph. 4. Para. 11.14 (a) – (c) Para. 11.14 (a) and (b) Redrafting to provide clarity on utilisation of soft commission. 5. Para. 11.27
Para. 11.27 Redrafting to provide clarity on the expectations relating to the policies and procedures. 6. Para. 11.28 (a) – (e) Para. 11.28 (a) – (d) Redrafting to provide clarity on the consent/disclosure to be made and renumbering of sub-paragraphs (b) and (c) in order of execution. 7.
Para. 11.30 Inclusion of requirement for compliance officer to verify cross trades undertaken.