VCFM & the RFMC Repeal: The Venture Capital Fund Manager Regime
What the Venture Capital Fund Manager registration covers, why MAS repealed the RFMC regime on 1 August 2024, and which route a VC manager should take now.
A Venture Capital Fund Manager (VCFM) is a fund manager registered with the Monetary Authority of Singapore (MAS) to manage qualifying venture capital funds under a lighter-touch regime than a full Licensed Fund Management Company (LFMC). It carries no regulatory minimum base capital and a faster MAS review — reflecting that VC funds invest in illiquid, non-retail private companies. Separately, the older Registered Fund Management Company (RFMC) regime was repealed on 1 August 2024; the two are often confused.
This page untangles them: what the VCFM is, what changed when the RFMC was abolished, and how a VC manager should decide between registering its own VCFM and launching under an existing Permissible Fund Manager.
What is a VCFM and who is it for?
The VCFM regime is built for managers whose funds invest in early-stage and growth private companies. Because those investments are illiquid and the investors are sophisticated, MAS applies lighter prudential requirements: no minimum base capital, no risk-based capital ratio, and a streamlined registration. The trade-off is scope — a VCFM may only manage qualifying VC funds (broadly, funds investing in unlisted business ventures, not freely traded securities, with restrictions on redemptions and investor type). A VCFM that wants to run liquid or retail strategies must convert to a full LFMC.
VCFM vs LFMC — what's the difference?
| Feature | VCFM | A/I LFMC |
|---|---|---|
| What it can manage | Qualifying VC funds only | Broad fund management (accredited/institutional) |
| Base capital | No regulatory minimum | S$250k |
| Risk-based capital | Not applied | ≥120% |
| SG-based professionals | ≥2 | ≥2 |
| MAS review | ~4 months | ~6 months |
| Compliance burden | Lighter | Fuller compliance function |
The headline saving is capital and speed. The cost is flexibility: if your strategy might drift beyond qualifying VC, the full LFMC route avoids a later conversion.
Why was the RFMC regime repealed?
The Registered Fund Management Company was a general lighter-touch registration — not VC-specific — capped at S$250m AUM and 30 qualified investors. Over time MAS judged it redundant alongside the A/I LFMC and moved to simplify the framework. On 1 August 2024 the RFMC regime was repealed. Existing RFMCs were transitioned to A/I LFMC status through a streamlined Form 1AR process, and the old S$250k AUM cap was removed in the process. New managers can no longer register as an RFMC.
Was the VCFM affected by the RFMC repeal?
No — and this is the most common point of confusion. The RFMC and the VCFM are different regimes. The RFMC was the general lighter-touch registration that has now been abolished. The VCFM is a separate, VC-specific registration that remains current. If you manage qualifying VC funds, the VCFM is still very much available; only the RFMC is gone.
What changed for RFMCs after 1 August 2024?
- RFMC registration is closed to new applicants.
- Existing RFMCs moved to A/I LFMC status via the streamlined Form 1AR.
- The previous S$250m AUM cap no longer applies — transitioned managers can scale without that ceiling.
- The base capital floor for the resulting A/I LFMC is S$250k, with risk-based capital of at least 120%.
Should a VC manager register a VCFM or use an existing manager?
If you want your own regulated entity and your strategy is firmly within qualifying VC, the VCFM is the lean route — no base capital and a faster review. If you want to launch even faster, or you are not sure your strategy stays within VC limits, appointing an existing MAS-licensed Permissible Fund Manager lets you incorporate your VCC in weeks and skip the registration wait entirely. Many first-time VC managers launch under a manager, prove the fund, then register their own VCFM for fund II.
Launching a venture capital fund?
We partner with MAS-licensed CMS fund managers. Tell us your strategy and we'll map whether a VCFM or an existing manager gets you to first close faster.
Speak to a specialist →How this connects to the rest of your setup
The VCFM is one route to the "manager" building block in how to start a fund in Singapore; the wider licence map is on fund management licence: CMS, LFMC & VCFM. A VC fund typically pairs its manager with a VCC and a Section 13U or 13O tax exemption. Strategy-specific guidance lives on the venture capital VCC page.
Frequently asked questions
What is a Venture Capital Fund Manager (VCFM) in Singapore?
A VCFM is a MAS-registered fund manager confined to managing qualifying venture capital funds. The regime is lighter-touch than a full LFMC: there is no regulatory minimum base capital and MAS review is faster (around four months), reflecting that VC funds invest in illiquid, non-retail private companies.
When was the RFMC regime repealed?
The Registered Fund Management Company (RFMC) regime was repealed on 1 August 2024. Existing RFMCs were transitioned to Accredited/Institutional LFMC status through a streamlined Form 1AR process, and the old S$250k AUM cap was removed.
Is a VCFM the same as an RFMC?
No. The RFMC was a general lighter-touch registration capped at S$250m AUM, now repealed. The VCFM is a separate, still-current registration specifically for managers of qualifying venture capital funds. The VCFM was not affected by the RFMC repeal.
Does a VC fund need its own VCFM, or can it use an existing manager?
Either. A VC fund needs a MAS-regulated manager, but you can register your own VCFM or appoint an existing MAS-licensed Permissible Fund Manager and launch your VCC without your own registration — avoiding the application wait.
VCC Singapore is an independent informational resource and is not a regulator, law firm or tax adviser. The VCFM qualifying criteria and the RFMC transition rules are set by MAS and change periodically — confirm the current position before acting. This page is general information, not legal, tax or financial advice.