Singapore – MAS Fund Disclosure Practices

Singapore – MAS Fund Disclosure Practices

On 27 July 2020, SIN MAS issued good practices for actively managed funds.

  • Sets out good disclosure practices for actively managed funds, re investment objective and extent to which portfolio deviates or can deviate from reference benchmark.
  • Highlights findings from a thematic review on more than 100 equity funds with active management mandates offered by 19 fund management companies to retail investors.


  • Found that majority of fund disclosures covered in the thematic review were generic; management styles and extent of active management were not immediately apparent.
  • In almost all instances, reference benchmark was not mentioned and discussed under investment objectives, and its purpose was also not clearly set out in most instances.
  • Active share and tracking error often not disclosed in fund factsheets, prospectuses.

Good Practices

  • Clearly state that a fund is to be actively managed; clearer statement of purpose of reference benchmark would help investors better assess fund's performance vs peers.
  • Where a fund is not managed in reference to any benchmark, this should be clearly stated in the fund document, with accompany explanation on why one is not used.
  • Should provide clear disclosures on how investment limits and constraints can affect risks and expected returns of funds, such as degree of freedom relative to benchmark.
  • Should also disclose their funds’ active share and tracking error on a regular basis.