Who holds the money in a Singapore fund or yield product?

A Singapore fund is not one company. A manager invests the money, a separate trustee or custodian holds it, and the Code on Collective Investment Schemes says the trustee must be independent of the manager. Banks, registers and dealing routes fill the other roles, and each fund picks its own.

In five example funds Singapore investors can buy, the same few banking groups turn up around the fund. HSBC, Citi, DBS and State Street each hold more than one role, and HSBC and State Street each work on two of the five.

Start with how a fund is built, then see which firms five example funds use for each role and where the same names turn up twice.

S$6.7tn

Assets managed from Singapore at the end of 2025, in funds and in client mandates, up 10% on the year

MAS survey 31 Dec 2025
306authorised funds

Authorised funds across 118 registered prospectuses on the MAS list for the last 12 months

MAS OPERA list 8 Nov 2026
3,443sub-funds

Sub-funds held in 1,406 VCCs incorporated or re-domiciled in Singapore

MAS survey 31 Dec 2025
102unit trusts

Unit trusts a CPF member can buy with CPF money, 94 of them directly from the manager

CPF Board list 20 Jul 2026

How a Singapore fund is built

A fund is one pool of money, split into sub-funds and sold in classes.

Many investors, one pool Fund
Investors’ money pooled and invested as a single fund. A fund can stand alone, like a listed ETF, or sit under an umbrella.
One pool, many slices Unit or share
The ETF deed calls a unit one undivided share in the fund, and a VCC issues and redeems shares in the same way. The price starts from the value of all the assets less the liabilities.
One shell, multiple funds Umbrella
Seen in an umbrella unit trust that offers a range of sub-funds. In a VCC the sub-funds can share a board and service providers.
One umbrella, own pools Sub-fund
It has its own portfolio, and its money does not mix with the other sub-funds. MAS counts authorised funds and sub-funds together.
One pool, a price per class Class
Classes differ in currency, fees, minimums, income policy and who may buy, and each class gets its own price per unit.

same idea in both umbrellas how this structure differs not present

Umbrella unit trust

Umbrella
= One manager acts for the whole umbrella.

≠ A trust under a deed. The trustee holds the assets on trust for the holders.
Sub-fund
= Each sub-fund has its own assets and liabilities.

≠ Kept apart as separate trusts, each with its own register.
Class
= A sub-fund can offer several classes, each with its own price.

≠ Investors hold units in the trust.

Umbrella VCC

Umbrella
= One manager acts for the whole umbrella.

≠ A company under a constitution. A board of directors governs all the sub-funds, and a custodian holds the assets.
Sub-fund
= Each sub-fund has its own assets and liabilities.

≠ Kept apart by law, even in an insolvency, each with its own register.
Class
= A sub-fund can offer several classes, each with its own price.

≠ Investors hold shares in the company.

Standalone unit trust

Umbrella
∅ None. The SPDR STI ETF is a Singapore-constituted authorised standalone unit trust, so its manager and trustee act for that one fund.
Sub-fund
∅ None. The trust and the fund are the same thing.
Units
≠ A listed one has units that trade on SGX, created and redeemed in blocks through participating dealers. The trustee’s register names CDP as the holder of the units that trade.

How units are bought and sold

The United SGD Fund issues and redeems units on request. A listed fund differs. Dealers create and redeem units in blocks, and investors trade the units on SGX.

Who may buy it

One structure serves both, because a VCC can hold open-ended and closed-end funds, traditional and alternative.

Private use Private equity, venture capital, hedge funds and family offices, which are not sold to the public.

Public use Funds the public can buy only after MAS authorises them, and MAS lists them.

Who owns what

Investors own units, a claim on the fund. A unit trust’s trustee holds the fund’s assets on trust for the holders.

The roles around a Singapore fund

Only the manager and the trustee are required. The custody bank, register, valuation and dealing route are appointed by contract.

MAS Authorises each fund, licenses its manager and approves its trustee.

Required Manager Runs the portfolio and deals with investors on the fund’s behalf.

Required Trustee or VCC custodian Legally holds the fund’s assets for investors, independent of the manager. A VCC has a VCC custodian instead.

The fund A sub-fund of an umbrella, or a standalone fund. A unit trust, a VCC or a listed unit trust.

ACRA Registers variable capital companies and administers their law.

Appointed Valuation Calculates the price per unit. A fund can do it itself or hand it to an administrator.

Appointed Custody bank Keeps the securities in its accounts. Appointed by the trustee or VCC custodian, which stays accountable.

Appointed Register of holders The legal list of who owns the units, kept by a registrar. Often the trustee, the VCC custodian or the custody bank.

CDP (SGX) SGX’s depository. Holds a listed fund’s units in its name and records who holds them.

Appointed Order networks Carry subscription and redemption orders between distributors and fund houses.

Appointed Distributors Banks, brokers and platforms that sell the fund and place the order.

Optional Advisers People and digital platforms that recommend funds or run a portfolio of them.

Payment banks Carry the investor’s payment to the trustee. Singapore dollar payments between banks settle at MAS in MEPS+.

Investor Retail or institutional. On the register or in a named account if direct, otherwise on a platform, adviser or broker’s books.

Expand to read the labels and lines.

Licenses, approves or registers
Holds assets or the register for
Manages, appoints or delegates to
Sells to or places orders for
Moves the cash

A trustee must be approved by MAS under section 289 of the Securities and Futures Act. Sixteen are listed.
MAS licenses each manager to carry on fund management, as a registered prospectus says of its manager.
MAS authorises the fund before it is offered to the public.
A variable capital company is regulated under the VCC Act, administered by ACRA.
The trustee must be independent of the manager. It is not if one person holds 20% or more of both.
The manager runs the portfolio under the deed or constitution, and answers for the fund to its holders.
The trustee, or the VCC custodian, safekeeps the fund’s property for its holders.
The trustee or VCC custodian appoints the custody bank, which prospectuses call the custodian. The Fullerton trustee appointed the global custodian, and a VCC custodian stays accountable when it delegates.
A manager can delegate accounting and valuation to the trustee or appoint a separate administrator.
Who keeps the register is a contract choice. In 88 of 118 registered prospectuses it is the trustee or custodian.
For a listed fund, the register names CDP as the registered holder of the units available for trading. Investors are not named on it one by one.
CDP’s Depository Register is where a listed unit’s owner is decided. A depositor named in it is deemed the owner, and the manager may rely on it. A depositor is a direct account holder or a depository agent, so an investor who holds through a broker or bank sits on that firm’s books.
The register shows conclusively who holds the units, except where a nominee is the registered holder.
A distributor takes the subscription and passes the order on, and the investor places the order with it.
The manager appoints distributors by contract and pays them commission for marketing units. A distributor sends orders to the manager, and an investor can also deal with the manager directly.
A distributor such as a bank or a life insurer appoints representatives, and each representative can have only one financial adviser. The adviser places the investor’s order through that firm, or through a platform it uses. A digital adviser is its own distributor.
An adviser recommends funds, or for a digital adviser such as DBS digiPortfolio can manage a discretionary account, and the investor can act through it.
A platform pools its customers. FSM Global’s terms say iFAST places consolidated orders with the manager, and the units are registered in its custodian’s name, not the customer’s. The investor is then on the platform’s books, not on the fund’s register.
The register is often kept by the trustee arm. In 88 of 118 registered prospectuses the trustee or custodian also keeps it, and the trustee appoints the registrar of a unit trust, while the company appoints it for a VCC.
A direct buyer pays for units from a bank account, or with SRS or CPF money through the operator or agent bank. Through a platform or broker, the investor funds it first and it pays from the cash it holds. Units are not issued until the trustee has the money in cleared funds.
A platform or broker usually holds the investor’s cash first. FSM Global’s terms put investment money in a cash account and make purchase payments payable to a client trust account. It then pays for the units through its own bank.
The money lands with the trustee, or in the sub-fund’s account for a VCC. The trustee must receive it in cleared funds before units are issued.
Singapore dollar payments between banks settle at MAS in MEPS+. CDP also settles Singapore dollars through it.
Orders between distributors and the fund house can travel by Calastone or SWIFT, or by fax.
The manager can offer the fund through a network, and orders come back the same way. A prospectus names Calastone and SWIFT as the electronic mode and fax as the manual one.

The firm each example fund uses for each role

Five example funds under Singapore law that MAS lists as authorised, and the firm each one names.

Fund ManagerTrustee or VCC custodianCustody bankAdministratorRegister kept by

Fullerton SGD Cash Fund

Sub-fund of the Fullerton Fund, a unit trust S$10.05 billion at 30 September 2026

Fullerton Fund Management Company

HSBC Institutional Trust Services

HSBC Appointed by the trustee

HSBC Institutional Trust Services Delegated by the manager

HSBC Institutional Trust Services The trustee is the registrar

DBS CIO Liquid+ Fund

Sub-fund of Scalar Retail Fund VCC US$1.08 billion at 30 June 2026

DBS Bank

Citicorp Trustee (Singapore) VCC custodian

Citibank N.A., Singapore Branch Master sub-custodian

Citibank N.A., Singapore Branch

Citicorp Trustee (Singapore)

SPDR STI ETF

Unit trust listed on SGX S$3.80 billion on 6 November 2026

State Street Global Advisors Singapore

DBS Trustee

State Street Bank and Trust Company

State Street Bank and Trust Company Delegated by the manager

DBS Trustee Keeps the Register of Holders. CDP keeps the Depository Register

United SGD Fund

Sub-fund of United Short Duration Portfolios, a unit trust S$3.46 billion on 8 November 2026

UOB Asset Management

State Street Trust (SG)

State Street Bank and Trust Company Global master custodian

State Street Bank and Trust Company

LionGlobal Singapore Trust Fund

Authorised unit trust S$2.77 billion on 8 November 2026

Lion Global Investors

HSBC Institutional Trust Services (Singapore)

HSBC

HSBC Institutional Trust Services

How a Singapore fund is built

Umbrella unit trust

Umbrella VCC

Standalone unit trust

How units are bought and sold

Who may buy it

Who owns what

The roles around a Singapore fund

Key facts

By the numbers

Lists and registers used here

How the counts were made

Key facts

What the rules require

50 or more funds

20 to 30 funds

10 to 19 funds

5 to 9 funds

2 to 4 funds

1 fund

Key facts

What the rules require

By the numbers

Named as trustee or VCC custodian in the registered prospectuses

Approved by MAS, none found in those prospectuses

How the trustee, custody bank and register relate

Who counts as independent

Why a VCC has a custodian

Key facts

What the rules require

Key facts

By the numbers

Where to look

Key facts

What the rules require

Named as administrator in the registered prospectuses

Key facts

What the rules require

Named as custodian, the custody bank, in the registered prospectuses

How the trustee, custody bank and register relate

Key facts

What the rules require

Trustee arms, VCC custodians and custody banks that keep it, as named in the prospectuses

How the trustee, custody bank and register relate

Who the register names

Key facts

Owner

Key facts

What the rules require

Networks and channels named

Market makers for a listed ETF

Who owns the networks

Key facts

What the rules require

CPFIS-OA agent banks

Brokerages and platforms, from their own pages

Distributors that joined Calastone, 2012

Key facts

What the rules require

By the numbers

Licensed advisers carrying insurers’ names, in MAS’s directory

Digital advisers, from their own pages

Key facts

Where to look

Key facts

By the numbers

Where an investor can be named

How a purchase is recorded

The firm each example fund uses for each role

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