How the compliance options compare.
Three legitimate models for a Singapore fund manager: an in-house Compliance Officer, an outside adviser on retainer, or Rook alongside your directors. Each fits different firms at different stages.
"The compliance function should be adequate and effective, having regard to the nature, scale and complexity of the FMC's business. Where the function is outsourced, the FMC's board and senior management remain responsible and must satisfy themselves that the service provider has the capacity, competence and independence to discharge the function effectively."
Paraphrased from MAS Guidelines on Licensing and Conduct of Business for Fund Management Companies, amended 23 February 2024, consolidated 13 January 2025. Read the source
Three models, side by side
A factual comparison of what each option gives you day-to-day. None of these is inherently 'right' — the fit depends on your firm's stage and complexity.
| Dimension | In-house CO | Outside adviser (retainer) | Rook |
|---|---|---|---|
| Typical annual cost (LFMC) | SGD 150k+ | SGD 18–48k | SGD ~948–2,988 |
| Response time on a rules question | Same day | Hours to days | Seconds, cited |
| Deadline tracking | Owned internally | Managed by adviser | Automated calendar |
| Policy drafting | Bespoke, in-house | Drafted by adviser | AI first draft, you edit |
| Audit trail | Depends on process | Depends on firm | Built in, timestamped |
| Best fit | Larger firms with capacity for a dedicated hire | Firms wanting a named human relationship | Firms that want to keep control while cutting the repetition cost |
Many firms use a combination — for example, Rook for day-to-day tracking and drafting, plus an outside adviser or lawyer for judgement calls and formal sign-offs.
Whichever model you pick, the accountability stays with the board.
MAS holds the FMC's board and senior management responsible for compliance — regardless of who drafted the policy or filed the form.
Where a company contravenes the Securities and Futures Act, every officer who consented to, connived in, or whose neglect contributed to the contravention is personally liable.
Senior managers must be clearly identified and held to specified responsibilities — including oversight of compliance, whether the function is in-house or outsourced.
Board and senior management retain ultimate responsibility for outsourced functions, and must ensure adequate due diligence, monitoring, and contingency arrangements.
Source links: SFA · IAC Guidelines · Outsourcing Guidelines
AI does the typing. You keep the judgement.
Rook removes the repetition. The director still reads, edits and signs.
MAS-grounded policy with paragraph-level citations.
Edge cases and judgement calls surfaced for the reviewer.
Reviewer assigns, edits, and locks the version.
Full provenance, ready for the next MAS query.
See what Rook costs.
Two free calculators put numbers on the day-to-day compliance spend — and a third helps pre-licence firms model their application costs.
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