MAS consults on proposed revisions to Guidelines on Liquidity Risk Management Practices (Fund Management Companies)

28 January 2026

On 17 December 2025, the Monetary Authority of Singapore (“MAS”) issued its Consultation Paper on Updates to the Guidelines on Liquidity Risk Management Practices (Fund Management Companies). The consultation closes on 28 February 2026.

The Guidelines on Liquidity Risk Management Practices for Fund Management Companies (“LRM Guidelines”) were issued in 2018 to provide guidance on sound practices in managing liquidity risks in collective investment schemes (“CIS”). Since 2018, global financial market events and market volatility brought on by geopolitical factors have highlighted (i) the need for regulators to provide further guidance to strengthen the alignment between portfolio liquidity and redemption terms of CIS, (ii) the importance of having a comprehensive toolkit of liquidity management measures (including the use of anti-dilution liquidity management tools (“ADTs”)), and (iii) that investor redemptions are not the only source of potential liquidity demands for a CIS.

MAS proposes to clarify its expectations on some aspects of the existing LRM Guidelines, including:

  • the removal of exchange-traded funds from the scope of the LRM Guidelines;
  • alignment between redemption terms and liquidity of fund assets;
  • the adoption of ADTs;
  • the incorporation of explicit and implicit costs, including market impact of asset sales into redemption costs;
  • strengthening governance and enhancing disclosures on the design and use of liquidity management tools; and
  • a holistic assessment of liquidity risks.

The updated LRM Guidelines are consistent with the Final Report on Revised Recommendations for Liquidity Risk Management for Collective Investment Schemes issued by the International Organization of Securities Commissions in May 2025, and the Final Report on Liquidity Preparedness for Margin and Collateral Calls issued by the Financial Stability Board in December 2024.

MAS also proposes to update the Code on Collective Investment Schemes (“CIS Code”) to strengthen portfolio liquidity in money market funds by introducing expectations on eligible deposits that are placed with financial institutions.

MAS proposes that the updates to the LRM Guidelines and CIS Code come into effect six months after the revised LRM Guidelines are published.

Reference materials

The Consultation Paper on Updates to the Guidelines on Liquidity Risk Management Practices (Fund Management Companies) is available on the MAS website www.mas.gov.sg.