i OVERVIEW OF RECENT ACTIVITY

Singapore's assets under management (AUM) continued to experience year-on-year growth, reaching an amount of S$2.7 trillion (US$1.9 trillion) AUM in 2016, according to the Monetary Authority of Singapore's (MAS) annual asset management survey published in late 2017.2 In particular, in line with global trends, Singapore's alternative sector AUM, comprising hedge funds, venture capital, private equity and real estate, experienced strong growth, increasing by 17 per cent.3

Currently, Singapore has over 700 registered and licensed fund managers. The availability of tax incentives, licensing requirements that are not very stringent, and the number of high-net-worth individuals are just some of the factors inducing fund managers and funds to set up in Singapore. Other factors include a highly skilled workforce, stable political environment and world-class infrastructure.

As part of Singapore's efforts to cement its position as one of the leading hubs for asset management in Asia, the MAS recently implemented the venture capital fund manager (VCFM) regime, and plans to unveil a new corporate structure for investment funds called the Singapore variable capital company (S-VACC) next year. The VCFM regime is part of the MAS's efforts to deepen Singapore's venture capital capabilities and establish itself as a vibrant enterprise financing hub. Venture capital managers who can avail themselves of the VCFM regime will be exempt from many regulatory requirements that apply to licensed fund managers. The introduction of the S-VACC will transform Singapore's fund vehicle landscape by permitting investors to enter and exit from a fund at its net asset value, and allowing funds to freely redeem shares and pay dividends using their net assets and capital, thereby providing flexibility in the distribution and return of capital. This is in contrast to the restrictions currently experienced by private limited companies (one of the commonly utilised fund structures in Singapore), as the Companies Act4 imposes various restrictions on the reduction of capital and the ability to pay dividends. The S-VACC will also allow for segregated cells to be created in a single company, facilitating umbrella funds to be formed using a single company.

At the same time, the MAS has made sure that in a constantly evolving market, strict standards of financial regulation continue to be implemented so that financial institutions and global investors can carry on conducting fund management activity in Singapore with confidence. The Securities and Futures (Amendment) Act 2017 (SFA(A)), which will come into force shortly, will bring into effect enhanced regulatory safeguards for retail investors, an opt-in regime for accredited investors and requirements for over-the-counter derivatives to be cleared on central counterparties, thereby reducing counterparty credit risks and making the trading of over-the-counter derivatives in Singapore safer. The SFA(A) will also enhance the credibility and transparency of the capital markets by introducing a new regulatory framework for financial benchmarks and strengthening disclosure requirements for short selling of listed securities.

II GENERAL INTRODUCTION TO REGULATORY FRAMEWORK

The primary legislation for the regulation of asset management activity in Singapore is the Securities and Futures Act5 (SFA). The MAS regulates all financial institutions in Singapore, including fund managers.

Fund management is a regulated activity defined under the Second Schedule of the SFA. The SFA defines fund management broadly:

undertaking on behalf of a customer (whether discretionary authority granted by the customer or otherwise) –
(a) the management of a portfolio of securities or futures contracts; or
(b) foreign exchange trading or leveraged foreign exchange trading for the purpose of managing the customer's funds,

but does not include real estate investment trust management.6

Once the SFA(A) comes into force, the definition of fund management will be broadened to include 'managing the property of, or operating, a collective investment scheme',7 with the consequence that the regulated activity of fund management will no longer be limited to portfolio management of financial products.

Real estate investment trust management is defined separately in the SFA, although the management of a fund will not be considered as real estate investment trust management unless its units are listed for quotation on a securities exchange.8 Rather, it would fall to be regulated as fund management.

Under Section 82 of the SFA, any person who conducts fund management in Singapore is required to hold a capital markets services (CMS) licence, or must fall within an exemption to hold a CMS licence. A frequently utilised exemption is the registered fund management company (RFMC). Where a corporation carries on fund management in Singapore on behalf of not more than 30 qualified investors, of which not more than 15 are collective investment schemes (CIS), close-end funds or limited partnerships, and where the total AUM do not exceed S$250 million, the fund manager need not hold a CMS licence if it is registered with the MAS as a RFMC.9 Another frequently utilised exemption is the 'immovable property exemption',10 which applies to funds investing directly or indirectly only in immovable assets if all the investors in the fund are 'qualified investors',11 a term that ultimately refers to accredited investors12 and institutional investors.13

Licensed fund management companies (LFMCs) may be divided into two categories: retail LFMCs, which may conduct fund management for all types of investors, and accredited/institutional investor LFMCs (A/I LFMCs), which can only conduct fund management for qualified investors.

A/I LFMCs and RFMCs are subject to various criteria for licensing or registration, including the following:14

  1. a the requirement to have a minimum base capital of S$250,000;
  2. b key personnel requirements:
    • the board of the A/I LFMC/RFMC must have at least two directors with a minimum of five years' relevant experience, one of which must be an executive director who is resident in Singapore and employed full-time to oversee the operations of the company;
    • the fund management company must appoint a CEO with a minimum of five years' experience;
    • the fund management company must have at least two relevant professionals and two representatives who are ordinarily resident in Singapore ('relevant professionals' refers to experienced fund management professionals with at least five years of relevant work experience and 'representatives' refers to junior fund management professionals who conduct fund management activities);
  3. the requirement to put in place an independent compliance division with staff that are suitably qualified, and where the AUM exceed S$1 billion, an independent and dedicated compliance division;
  4. a risk management framework appropriate for the nature and scale of the fund management company that identifies, addresses and monitors the risks associated with the assets under management; and
  5. internal audit requirements that are adequate and commensurate with the scale, nature and complexity of the fund management company's operations.

Professional indemnity insurance is not mandatory for an A/I LFMC or RFMC, although the existence or non-existence of such insurance is required to be disclosed to investors. A/I LFMCs and RFMCs are also subject to operating requirements such as business conduct requirements, anti-money laundering and countering the financing of terrorism requirements, and third-party service providers requirements.

As mentioned above, the VCFM regime recently came into effect. Under the VCFM regime, venture capital managers are still required to hold a CMS licence. However, the application process is shortened and simplified, and regulatory requirements such as business conduct, base capital, risk-based capital and competency of key individuals requirements are removed. To qualify under the VCFM regime, a venture capital manager must only manage funds that:

  1. invest at least 80 per cent of committed capital in securities that are directly issued by unlisted business ventures, and that have been incorporated for no more than 10 years at the time of the fund's initial investment;
  2. invest up to 20 per cent of their committed capital in other unlisted businesses that do not meet the criteria in (a);
  3. are not continuously available for subscription and are not redeemable at the investors' discretion; and
  4. are offered only to accredited or institutional investors, or both.15

Investment funds fall within the ambit of a CIS under the SFA. Under Section 285 of the SFA, offers of units in a CIS cannot be made unless the CIS is authorised or recognised under Section 296 of the SFA, and offers of units in a CIS must be accompanied by a prospectus prepared in accordance with requirements prescribed by the MAS. However, Subdivision 4 of the SFA provides exemptions from the authorisation and prospectus requirements. For example, where the units in a CIS are offered to accredited investors or certain other persons, there is a prospectus exemption under Section 305 of the SFA (Section 305 exemption) (where the Section 305 exemption is used, only a simple notification of the proposed offer of the interest has to be filed with the MAS before it is offered to such investors in Singapore), or, where the units in a CIS are offered only to institutional investors, the prospectus exemption under Section 304 of the SFA may be utilised (in which case, no notification requirement arises). Two other notable exemptions are the small offers exemption under Section 302B of the SFA and the private placement exemption under Section 302C of the SFA.

iii COMMON ASSET MANAGEMENT STRUCTURES

Singapore law offers a variety of structures for funds. While the structure of the fund depends on the type and location of underlying investments and the nature of the investors, most commonly a company registered under the Companies Act, a limited partnership registered under the Limited Partnership Act16 and a unit trust are utilised.

i Private limited companies

A private limited company incorporated in Singapore can be used as a fund vehicle. Where a fund is a private limited company, it has separate legal personality from its members, so members are not responsible for the debts and obligations of the company, and are only liable to the extent of any amount unpaid on their shares. Under the Companies Act, share buybacks can only be carried out in relation to 20 per cent of any class of the issued capital of a company.17 Further, buybacks may be made out of capital only if a company can show that it will continue to remain solvent for the following 12-month period.18 Other forms of capital reduction require the directors of a company to make a statutory solvency statement or otherwise attain the approval of the court.

ii Limited partnerships

A limited partnership consists of at least one general partner and one limited partner. The investor, as limited partner, will enjoy limited liability for the debts and obligations of the partnership. The fund manager, as general partner, is liable for all debts and obligations incurred by the limited partnership while it is a general partner. However, in a fund structure, the general partner will usually be a limited liability entity formed by the fund manager's principals. An advantage of structuring the fund as a limited partnership is that there is no requirement to produce a solvency statement when reducing capital. Further, the structure is subject to significantly fewer regulatory constraints compared to a corporate structure, as the partnership agreement is only lightly regulated.

iii Unit trusts

The unit trust is also a very common fund structure in Singapore, and follows the English unit trust model. It can be distinguished from a company and limited partnership in that the trust property is vested in a trustee via a special form of trust constituted by a trust deed. Under a unit trust, the trustee is bound by the directions of the fund manager, and acts for and holds the trust property for the benefit of the unit holders. The unit trust is the preferred structure for retail funds.

iv S-VACCs

The S-VACC, when implemented, will be the first corporate structure available in Singapore that is geared towards investment funds. Aside from having an open-ended capital framework, other key features of the S-VACC include the ability to use US GAAP accounting standards, and the option for the S-VACC to be used either as a standalone fund structure or as an umbrella fund structure with multiple sub-funds that have segregated assets and liabilities. Further, the register of holders of an S-VACC will only have to be disclosed to regulatory and public authorities: it will not have to be disclosed to the public.19 Similarly to the other existing fund structures in Singapore, the S-VACC will require a Singapore-based fund manager licensed or regulated by the MAS. The features of the S-VACC will allow fund managers to consolidate their fund management activities in Singapore.

iv MAIN SOURCES OF INVESTMENT

In 2016, Singapore had AUM of S$2.7 trillion, with 78 per cent of the total AUM sourced from outside Singapore. This figure is slightly lower than the percentage of 80 per cent recorded in 2015.20 Out of the total AUM, 55 per cent was sourced from the Asia Pacific region, 19 per cent was sourced from North America and 17 per cent was sourced from Europe. The total inflow of funds into Singapore in 2016 itself amounted to S$116 billion. The bulk of this inflow was attributed to real estate, private equity and venture capital fund managers, with AUM of the respective sectors experiencing growth rates of 32, 14 and 30 per cent.21

The 2016 Singapore Asset Management Survey also reports a growing pool of institutional investors using Singapore as a base to access global market opportunities. The AUM of institutional investors in Singapore increased to S$172 billion in 2016, representing 6 per cent of the total AUM in Singapore.22 The retail investment industry also experienced growth by 6 per cent, with the fund size of authorised CIS increasing to S$82 billion. While recognised CIS are schemes constituted outside Singapore, authorised CIS are constituted in Singapore and offered to retail investors in Singapore.

v KEY TRENDS

Fund managers in Singapore are increasingly utilising technology for asset management: for example, using artificial intelligence and data analytics to identify investment opportunities and generate trading strategies, and using robo-advisers and digital distribution channels to increase fund penetration and automate back-end processes.23 The MAS is aware that growing usage of technology presents heightened cyber risks, and intends to provide more specific guidance in relation to technology risk management.24

While it is relatively nascent in Asia, there is evidence of increased demand for sustainable investing in Singapore. According to Standard Chartered Private Bank's Asia Sustainable Investing Review 2018,25 investors in Singapore have the strongest understanding of sustainable investing in Asia, and 79 per cent of Singapore's high-net-worth investors are currently engaged in sustainable investing. Around 64 per cent of Singapore investors are highly motivated to do good and earn a profit at the same time by making sustainable investments. A greater understanding among investors that financial gains need not be sacrificed to have a positive impact might be key to further developing the ecosystem and moving sustainable investing into the mainstream.

Further, in its bid to restore public trust in financial institutions following several high-profile cases of ethical misconduct that were at the root of the global financial crisis, the MAS will continue to focus on mitigating malpractices in the asset management industry. Rather than solely assessing a fund manager's compliance framework, the MAS will engage fund managers in understanding how they embed desired conduct and culture in their everyday operations. This includes having practices in place to ensure employees are aware of risk boundaries, that employees are being held accountable for their actions, and that employees are empowered to speak up when they suspect or encounter malpractices. The best practices can serve as a point of reference for the asset management industry.26

vi SECTORAL REGULATION

i Insurance

Faced with increased competition, costly regulatory changes and low interest rates, insurers are revisiting their asset allocation strategies and turning to higher-yielding assets. Previously favoured assets such as bonds and loans are making way for alternative assets such as private equity, hedge funds and infrastructure. There has also been an increasing number of life insurance companies setting up dedicated asset management arms,27 with some of the largest insurers in the region basing the headquarters of their asset management arm in Singapore. Setting up a dedicated fund management arm would bring benefits such as allowing insurance companies to attract better fund management talent, and also avoiding high fund management fees.

Insurance companies carrying on their business in Singapore (registered insurers) are required to be licensed by the MAS under the Insurance Act.28 Although the definition of fund management under the SFA is constituted broadly and might cover the carrying out of insurance business, registered insurers are exempt persons under Section 99 of the SFA, and thus are exempt from holding a CMS licence.

In relation to investments of insurance funds, registered insurers are classified as institutional investors under the SFA,29 and thus enjoy access to a wider range of investment products. Under the Insurance Act, registered insurers are required to maintain separate funds for separate classes of policies,30 and are required to seek the prior approval of the MAS before holding directly or indirectly any stake in any corporation.31

Generally, registered insurers enjoy flexibility in the type of investments they choose to make. However, they must observe the fund solvency and capital adequacy requirements set out in the Insurance (Valuation and Capital) Regulations 2004. Further, MAS Notice 125 governs the oversight of investment activities, and requires registered insurers to establish an investment committee approved by the board of directors to oversee its investment activities.32 The investment committee must report to the board of directors no less than once every quarter and must carry out its investments in accordance with an investment policy approved by the board of directors. The registered insurer must also put in place a board-approved asset liability management policy that takes into consideration its investment management and product development and pricing functions. Further, registered insurers must comply with MAS Notice 126, which deals with risk management practices.33

ii Pensions

Singapore's pension scheme is administered by the Central Provident Fund (CPF) Board, which is a statutory board, and only applies to Singapore citizens and Singapore permanent residents. It is basically a compulsory savings scheme whereby each month, an employee will contribute 20 per cent of his or her salary and his or her employer will contribute an additional 17 per cent of the employee's salary (up to certain limits) into the employee's CPF account. Contribution rates may vary according to the age group of the employee. These contributions are credited to three CPF accounts, namely, the ordinary account, the special account and the medisave account. After turning 55, CPF members may withdraw their CPF savings after setting aside the requisite CPF minimum sum in a new account that will be created, called the CPF retirement account. The details of the CPF scheme are set out in the Central Provident Fund Act.34

CPF monies are invested by the CPF Board in special government securities that are issued and guaranteed by the government.35 The proceeds from the special government securities are ultimately pooled and invested together with the rest of the government's funds by the GIC, which is Singapore's sovereign wealth fund. As of 2018, the total amount of money in the CPF scheme is S$368,453.7 million.36

Where a CPF member chooses to let the CPF Board manage their monies as per the above, the member earns a risk-free return of about 3 to 5 per cent. However, where CPF members have more than S$20,000 in their ordinary account or more than $40,000 in their special account, or both, they are provided with an option to invest monies above that amount under the CPF investment scheme. Under the CPF investment scheme, CPF members have access to a wide range of investment products; however, they undertake these investments at their own risk. The investments that CPF members may make under the CPF investment scheme are regulated under the Central Provident Fund (Investment Schemes) Regulations.37

iii Real property

As mentioned above, an exemption to the requirement to hold a CMS licence to conduct fund management is the 'immovable property exemption'.38 A fund manager need not be registered or licensed by the MAS if it manages a fund that invests solely in immovable assets, or in securities issued by investment holding companies whose sole purpose is to invest into real estate development projects or real estate properties, if the fund is offered only to accredited investors, institutional investors, or to both. This is regardless of:

  1. the size of the company's stake in the real estate projects;
  2. the relationship between the developer and the fund manager;
  3. the stage of completion of the project; and
  4. the receipt of any subsequent income following the completion of the project.

However, if the fund manager is also engaged in the management of financial derivatives that fall within the definition of 'securities' or 'futures contracts' as defined in the SFA, this exemption will not apply and the fund manager will be subject to the licensing requirements set out in Section II.39

iv Hedge funds

According to Ernst & Young's 2017 Global Hedge Fund and Investor Survey,40 hedge fund managers are actively innovating to improve operational efficiency and grow their asset base, as pressure on margins remain and investors' appetite for innovative product offerings continue to grow. This growing interest in computer-driven strategies is reflected in Singapore, with reports of quant hedge fund activity on the rise.

Hedge fund managers in Singapore are subject to the licensing requirements and regulatory framework set out in Section II. While hedge fund managers are required to hold a CMS licence to conduct fund management activity in Singapore, hedge fund managers with relatively smaller levels of AUM often utilise the RFMC exemption (see Section II for further details) . It should be noted that for the purpose of counting the number of 'qualified investors' in a RFMC, a hedge fund seeking to utilise the RFMC exemption will be regarded as one 'qualified investor'.

Despite the many fund structures available in Singapore, many hedge fund managers seeking to operate in Singapore prefer to utilise the Cayman Islands company. This is due to the restrictions imposed on the Singapore private limited company in relation to the return of capital to investors, details of which are set out in Section III. In contrast, when using the Cayman Islands company, such constraints do not apply. Until the introduction of the S-VACC, which will allow for flexibility in returning capital to investors, it is likely that fund managers will continue to prefer using the Cayman Islands company.

v Private equity

Singapore's private equity sector has experienced rapid growth of 28 per cent over the past five years. This can be attributed to the trend of start-ups tending to stay private for longer, with an MAS survey reporting that successful Singapore-based start-ups tend to stay private for about eight years before listing.41

Many private equity fund managers base their operations in Singapore due to the various tax exemption schemes available (see Section VII).

Private equity fund managers are similarly subject to the licensing requirements and regulatory framework set out in Section II. There are no legal or regulatory rules that apply specifically to private equity fund activity in Singapore.

vii TAX LAW

i Taxation of funds

As long as a person managing a fund on a discretionary basis is present in Singapore, the fund is deemed to be resident for all tax purposes. This holds true whether the fund is located offshore or onshore.

While there is no tax on capital gains in Singapore, if gains from the disposal of investments are connected with activities of a trade or business carried on in Singapore, such gains may be considered to be of an income nature and sourced in Singapore, and thus might be subject to income tax.42 Funds incorporated as companies resident or deemed resident in Singapore are taxed at a fixed rate of 17 per cent on their chargeable income.43

Although this makes Singapore's tax system appear unfavourable, there are actually various tax incentives in place that make Singapore an ideal jurisdiction for fund domiciliation.

Singapore-resident fund schemes

Under Section 13R of the Singapore Income Tax Act (SITA),44 an onshore fund is exempt from tax on specified income and designated investments if the fund is an 'approved company'. This exemption only applies to companies. A fund will generally be an approved company if:

  1. the issued shares of the company are not 100 per cent owned by persons who are Singapore citizens;
  2. the fund manager is registered with the MAS, and holds a CMS licence or is exempt from holding one;
  3. all of the fund administration is done in Singapore;
  4. the fund has a minimum of S$200,000 local business spending per year; and
  5. the MAS approves of the tax exemption, and there is no change in investment strategy or objective after such approval by the MAS.

This scheme was introduced to encourage funds to be based in Singapore.

Offshore funds scheme

Under Section 13CA of the SITA, an offshore fund managed by a Singapore-based fund manager will be exempt from tax on income from designated investments if the fund is a 'prescribed person'. This exemption applies to funds that are companies, and to trusts. A fund will generally qualify as a 'prescribed person' if it is an offshore fund and is not 100 per cent owned by Singapore investors. Additionally, Singapore resident non-individual investors are limited to holding 30 to 50 per cent of the fund to enjoy the Section 13CA tax exemption on their share of the fund's income. Otherwise, they have to pay a penalty equivalent to the corporate tax to the Inland Revenue Authority of Singapore (IRAS).

Enhanced-tier fund scheme

Like the Singapore-resident fund scheme and the offshore fund scheme, the enhanced-tier fund scheme under Section 13X of the SITA provides a tax exemption for income and gains on designated investments. However, its main advantage is that there are no restrictions on the percentage of Singapore investors in the fund, no restrictions on the domicile of the fund, and funds structured as companies, limited partnerships and trusts can utilise the scheme if they receive approval by the MAS. Generally, a fund will receive approval if:

  1. the fund has a minimum size of S$50 million;
  2. the fund is managed by a Singapore-based fund manager;
  3. the manager employs at least three investment professionals;
  4. all the fund administration is done in Singapore; and
  5. the fund incurs at least S$200,000 in local business spending per year.

The above tax exemptions are currently available until 31 March 2019. It should be noted that Singapore limited partnerships are not treated by IRAS as legal persons, and therefore no tax is levied at the partnership level. Rather, the share of income accruing to each partner from the limited partnership will be taxed at the rates applicable to them. Additionally, it should be noted that a limited partnership cannot obtain benefits under Singapore's tax treaties (and would need to set up a company underneath it in the fund structure for that purpose).

ii Taxation of fund managers

A fund manager in Singapore is usually structured as a private limited company, and is taxed at a flat rate of 17 per cent on its chargeable income regardless whether it is a local or foreign company.

Under the financial sector incentive–fund management scheme (FSI-FM), fee income derived by an approved Singapore-based fund manager from the provision of prescribed fund management services to a qualifying fund in respect of designated investments is subject to a concessionary tax rate of 10 per cent. Generally, a fund manager will be able to use this tax incentive if it holds a CMS licence or is exempt from holding one, employs at least three investment professionals and has a minimum of S$250 million AUM. The FSI-FM Scheme was recently extended until 31 December 2023.

iii Taxation of foreign investors

The tax treatment of foreign investors only becomes relevant where a fund is not able to invoke any of the tax exemptions above.

There is no withholding tax on dividend distributions paid to foreign investors by funds structured as Singapore companies. However, a withholding tax rate of 2245 and 10 per cent, respectively, will be applicable if any interest or royalty is paid by the fund to the foreign investor.

As previously mentioned, where a fund is structured as a partnership, tax is levied at the partnership level. Profits of the partner will be treated as personal income and subject to personal income tax rates.46 Where the foreign partner is a natural person, there is no withholding tax on income from its profits from the fund. However, if the profits are derived from payment of any interest or royalty from the fund to the foreign partner, there will be a withholding tax rate of 22 and 10 per cent, respectively. Where the partner is a foreign corporation, profits of the partner will be subject to withholding tax at a rate of 17 per cent.47 However, in view of the difficulties involved in strictly complying with withholding tax requirements for partnerships, Section 45 of the SITA waives the requirement where the partnership has at least one Singapore-resident partner. Where all the partners are non-resident partners, this requirement will be waived if the partnership submits an undertaking that the head office of the partnership shall be liable for any outstanding tax arising from the waiver.

viii OUTLOOK

The MAS expressed in the 2016 Asset Management Survey that it will continue to work with the industry to deepen the financing ecosystem for regional and local companies. The MAS is looking to widen the talent pool, enhance ancillary professional services and build a pipeline of alternative market platforms to facilitate pre-IPO exits and capital recycling.


Footnotes

1 Amit Dhume and Bill Jamieson are partners and Joy Tan is a practice trainee at Colin Ng & Partners LLP.

3 Ibid.

4 Companies Act (Cap 50).

5 Securities and Futures Act (Cap 289).

6 Securities and Futures Act, Second Schedule Part II.

7 SFA Amendment Act 2017 s 193(f), amending SFA Second Schedule Part II.

8 Securities and Futures Act, Second Schedule Part II.

9 Securities and Futures (Licensing and Conduct of Business) Regulations, Second Schedule, Paragraph 5(1)(i).

10 Securities and Futures (Licensing and Conduct of Business) Regulations, Second Schedule, Paragraph 5(1)(h).

11 Securities and Futures (Licensing and Conduct of Business) Regulations, Second Schedule, Paragraph 5(3).

12 Securities and Futures Act (Cap 289), s 4(a).

13 Securities and Futures Act (Cap 289), s 4(c).

14 Guidelines on Licensing, Registration and Conduct of Business for Fund Management Companies, SFA04-G05.

15 Guidelines on Licensing, Registration and Conduct of Business for Fund Management Companies, SFA04-G05, Appendix 7.

16 Limited Partnership Act (Cap 163B).

17 Companies Act (Cap 50), s 76B(3).

18 Companies Act (Cap 50), s 76F.

20 2016 Singapore Asset Management Survey.

21 Ibid.

22 Ibid.

23 Ibid.

25 Asia Sustainable Investing Review 2018. Available at https://av.sc.com/corp-en/content/docs/Asia-Sustainable-Investing-Review-2018.pdf.

27 2016 Singapore Asset Management Survey.

28 Insurance Act (Cap 142).

29 Securities and Futures Act (Cap 289), s 4(c)(iv).

30 Insurance Act (Cap 142), s 17.

31 Insurance Act (Cap 142), s 30B.

32 MAS 125 Notice on Investments of Insurers.

33 MAS 126 Enterprise Risk Management for Insurers.

34 Central Provident Fund Act (Cap 36).

37 Central Provident Fund (Investment Schemes) Regulations, issued pursuant to Central Provident Fund Act (Cap 36) s 77(1)(n).

38 Securities and Futures (Licensing and Conduct of Business) Regulations, Second Schedule, Paragraph 5
(1)(h).

40 Ernst & Young 2017 Global Hedge Fund and Investor Survey: How will you embrace innovation to illuminate competitive advantages?

41 2016 Singapore Asset Management Survey.

44 Income Tax Act (Cap 134).