Focused comparison
Singapore custody/client assets vs United States custody/client assets
A focused comparison for custody/client assets businesses choosing between Singapore and United States.
| Question | Singapore | United States |
|---|---|---|
| Likely route | CMS custodial services and client asset safeguarding analysis | Investment adviser custody rule, qualified custodian, broker-dealer custody, and state custody analysis |
| Key people | Appointed representatives for regulated activities conducted on behalf of CMS licensees or exempt financial institutions Fit and proper assessment for directors, representatives, substantial shareholders, and key persons | Investment adviser representatives may require state registration depending on facts Broker-dealer registered representatives require firm sponsorship, CRD filing, exams, and registration |
| Corporate evidence | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers |
| Capital/resources | Capital and financial resource expectations depend on activity, client type, custody, and the specific licence or exemption path. | Adviser capital rules are usually state-specific or tied to custody and other facts; broker-dealers face SEC net capital and FINRA membership expectations. |
| Timeline | Typically 4 to 9+ months depending on route and readiness. | SEC adviser registration can become effective in about 45 days if complete; FINRA new member review may run up to 180 calendar days for substantially complete applications. |
| Common bottlenecks | Assuming accredited or institutional clients remove all licensing questions Weak explanation of investment strategy, risk management, or outsourced functions | Broker-dealer issues hidden inside compensation, solicitation, placement, or transaction workflows Custody, private fund audit, and fee deduction arrangements not fully analysed |