Paragraphs 11.15 and 11.28 of the Guidelines on Compliance Function for Fund Management Companies have been amended due to the liberalisation of the unit trust framework. This amendment will be effective from 1 March 2022.

The revised requirements relate to rebates and soft commissions. A fund manager, in accepting or receiving rebates or soft commissions, has a duty to ensure, among other things, that:

  • goods and services bring a direct benefit or advantage to the management of a client's investments;
  • transactions are executed according to terms that are most favourable to the clients; and
  • they do not enter unnecessary trades in order to achieve a sufficient volume of transactions to qualify for soft commission.

For further information on this topic please contact Pamela Kung at Shearn Delamore & Co by telephone (+60 3 2027 2911) or email ([email protected]). The Shearn Delamore & Co website can be accessed at