On 11 October 2012, MAS reprimanded Hupomone Capital Partners Singapore Pte Ltd [“HCPSPL”] for repeated late lodgments of Form 25 of the Securities and Futures (Licensing and Conduct of Business) Regulations [“SF(LCB)Regs”] after the end of its financial year. HCPSPL is an exempt fund manager under paragraph 5(1)(d) (now repealed) of the Second Schedule to the SF(LCB)Regs, undertaking fund management activity in Singapore on behalf of not more than 30 qualified investors.
Under the SF(LCB)Regs, the information to be filed in SF(LCB)Regs Form 25 includes the total assets under management of the exempt fund manager, and the total number of qualified investors on whose behalf the exempt fund manager undertakes such fund management activity. By failing to submit SF(LCB)Regs Form 25 within 14 days after its financial year end of 31 December 2011, HCPSPL has contravened paragraph 5(7)(d) (now repealed) of the Second Schedule to the SF(LCB)Regs. This was not HCPSPL’s first breach of the SF(LCB)Regs. HCPSPL was warned on three previous occasions, for its late submission of SF(LCB)Regs Form 25 for the financial years ended 31 December 2005, 31 December 2008 and 31 December 2010.