User Qualifications

For now, only accredited investors and institutional investors can invest in Auptimate's investment vehicles.

An accredited investor is:

• An individual whose:

  1. net personal assets exceed in value S$2 million (or its equivalent in a foreign currency); or

  2. financial assets (net of any related liabilities) exceed in value S$1 million (or its equivalent in a foreign currency); or

  3. income in the preceding 12 months is not less than S$300,000 (or its equivalent in a foreign currency).

• A corporation:

  1. with net assets exceeding S$10 million in value (or its equivalent in a foreign currency); or

  2. the entire share capital of which is owned by one or more persons, all of whom are accredited investors.

• The trustee of such trust (including a bare trust) as the MAS may prescribe, when acting in that capacity, being:

  1. any trust all the beneficiaries of which are accredited investors; or

  2. any trust all the settlors of which (i) are accredited investors, (ii) have reserved to themselves all powers of investment and asset management functions under the trust, and (iii) have reserved to themselves the power to revoke the trust; or

  3. any trust the subject matter value of which exceeds S$10 million (or its equivalent in a foreign currency).

• An entity (e.g. an unincorporated association, a partnership, or the government of any state) with net assets exceeding S$10 million in value (or its equivalent in a foreign currency).

• A partnership (other than a limited liability partnership) in which each partner is an accredited investor.

This is the definition of accredited investor under Singapore law. Other countries may have a different definition.

An institutional investor is a relatively small group, as it typically means an entity owned or controlled by a country’s central government or its central bank, or by a multilateral agency, international organisation or supranational agency (e.g. the International Monetary Fund or International Finance Corporation).

Under Singapore law, institutional investor means:

1. the Government;

2. a statutory board as may be prescribed by regulations made under section 341 of the SFA;

3. an entity that is wholly and beneficially owned, whether directly or indirectly, by a central government of a country and whose principal activity is:

   • to manage its own funds;

   • to manage the funds of the central government of that country (which may include the reserves of that central government and any pension or provident fund of that country); or

   • to manage the funds (which may include the reserves of that central government and any pension or provident fund of that country) of another entity that is wholly and beneficially owned, whether directly or indirectly, by the central government of that country;

4. any entity:

   • that is wholly and beneficially owned, whether directly or indirectly, by the central government of a country; and

   • whose funds are managed by an entity mentioned in sub‑paragraph 3. above;

5. a central bank in a jurisdiction other than Singapore;

6. a central government in a country other than Singapore;

7. an agency (of a central government in a country other than Singapore) that is incorporated or established in a country other than Singapore;

8. a multilateral agency, international organisation or supranational agency as may be prescribed by regulations made under section 341 of the SFA;

9. a bank that is licensed under the Banking Act 1970;

10. a merchant bank that is licensed under the Banking Act 1970;

11. a finance company that is licensed under the Finance Companies Act 1967;

12. a company or co‑operative society that is licensed under the Insurance Act 1966 to carry on insurance business in Singapore;

13. a company licensed under the Trust Companies Act 2005;

14. a holder of a capital markets services licence;

15. an approved exchange;

16. a recognised market operator;

17. an approved clearing house;

18. a recognised clearing house;

19. a licensed trade repository;

20. a licensed foreign trade repository;

21. an approved holding company;

22. a Depository as defined in section 81SF;

23. an entity or a trust:

    • formed or incorporated in a jurisdiction other than Singapore; and

    • which is regulated for the carrying on of any financial activity in that jurisdiction by a public authority of that jurisdiction that exercises a function that corresponds to a regulatory function of the MAS under this Act, the Banking Act 1970, the Finance Companies Act 1967, the Monetary Authority of Singapore Act 1970, the Insurance Act 1966, the Trust Companies Act 2005 or such other Act as may be prescribed by regulations made under section 341;

24. a pension fund, or collective investment scheme, whether constituted in Singapore or elsewhere;

25. a person (other than an individual) who carries on the business of dealing in bonds with accredited investors or expert investors;

26. the trustee of such trust as the MAS may prescribe, when acting in that capacity; or

27. such other person as the MAS may prescribe.

Other countries may have a different definition of institutional investor.

Under Singapore law, expert investor means:

1. a person whose business involves the acquisition and disposal, or the holding, of capital markets products, whether as principal or agent;

2. the trustee of such trust as the MAS may prescribe, when acting in that capacity; or

3. such other person as the MAS may prescribe.

Under Singapore law, qualified investor means:

1. an accredited investor, other than:

   • one who is a participant in a collective investment scheme mentioned in paragraph 2. below;

   • one who is a holder of a unit in a closed-end fund or in an arrangement mentioned in paragraph (aa) of the definition of “closed-end fund” in section 2(1) of the Securities and Futures Act as mentioned in paragraph 3. below;

   • one which is a corporation mentioned in section 4A(1)(a)(ii) of the Securities and Future Act or an entity mentioned in regulation 3(c) of the Securities and Futures (Classes of Investors) Regulations 2018:

     • • which is related to or controlled by a Registered Fund Management Company (RFMC), or a key officer or substantial shareholder of such entity; and

       • the shares or debentures of which are the subject of an offer or invitation for subscription or purchase made to any person who is not an accredited investor; or

   • a corporation or an entity which is a collective investment scheme or a closed-end fund the units of which are the subject of an offer or invitation made to any person who is not an accredited investor;

2. a collective investment scheme the units of which are the subject of an offer or invitation for subscription or purchase made:

   • in Singapore only to accredited investors, to institutional investors, or to both accredited investors and institutional investors; or

   • elsewhere if such offer or invitation is made only to accredited investors (or investors in an equivalent class under the laws of the country or territory in which the offer or invitation is made), to institutional investors, or to both accredited investors and institutional investors;

3. a closed-end fund or an arrangement mentioned in paragraph (aa) of the definition of “closed-end fund” in section 2(1) of the Securities and Futures Act, the units of which are the subject of an offer or invitation for subscription or purchase made only to accredited investors (or investors in an equivalent class under the laws of the country or territory in which the offer or invitation is made), to institutional investors, or to both accredited investors and institutional investors;

4. an institutional investor, other than a collective investment scheme; or

5. a limited partnership, where the limited partners comprise solely of accredited investors (or investors in an equivalent class under the laws of the country or territory in which the partnership is formed), of institutional investors, or of both accredited investors and institutional investors.

A retail investor is a person that does not qualify for any other type of investor, i.e. they are not an accredited investor, institutional investor or expert investor.

An investment professional is a person who performs the functions of portfolio management, research or dealing.  It does not include individuals solely involved in activities such as client servicing, business development, marketing or risk management.  For the avoidance of doubt, individuals whose roles are limited to middle-office or back-office functions would not be considered as investment professionals.