Two MAS changes land in January. Do you know which of your policies they break?

Two changes take effect for Singapore fund managers at the start of January 2027.

The first is the updated Guidelines on Liquidity Risk Management Practices for Fund Management Companies (SFA 04-G08), published on 2 July 2026, with firms expected to comply by 2 January 2027.

The second is Notice SFA 04-N24 on the reporting of misconduct of representatives, issued in December 2025. It takes effect on 1 January 2027 and replaces Notice SFA 04-N11.

Neither is a surprise. Both were published well in advance, which is how MAS usually works. The hard part was never finding out that something changed.

The hard part is the next question: which of our policies no longer cover this?

What that question actually costs

For a boutique fund manager with a one or two person compliance function, answering it means reading the new version, working out what is different from the version you were complying with, deciding which of those differences matter for your licence and your activities, then going through your own policy documents to see where each one is addressed, and recording what you concluded so you can show your board and, eventually, an inspector.

That is somewhere between one and three weeks of work, per change, done alongside everything else. And it repeats every time an instrument is amended.

Most firms do it well. They just do it slowly, in a spreadsheet, and the working is hard to reconstruct six months later when someone asks how the conclusion was reached.

Why most compliance software does not help here

Because most of it starts with an empty box.

The common model is that you upload your regulations, the tool extracts obligations, and you map your policies against them. That sounds reasonable until you notice what it asks of the customer. You have to know which notices, guidelines and circulars apply to your licence and regulated activities. You have to have the current version of each. You have to keep that collection up to date yourself.

That is the expertise the firm was trying to buy. Handing it back to them as data entry is not much of a solution.

A different starting point

We built RegRails.ai the other way around.

For a capital markets services licensee doing fund management in Singapore, the obligations are already loaded. The Securities and Futures Act and the conduct regulations, the AML notice, the technology risk and cyber hygiene notices, the fund management guidelines, the CIS Code for retail managers, and the rest. Each obligation is tagged at the level it actually applies, some across every firm under the regulator, some to the licence, some only to a specific regulated activity.

You set your regulatory profile. The obligations that apply to your firm are there on the first screen, with the source reference, the section, the version and the effective date attached to each one. Then you upload your policies, not your regulations.

And when the instrument changes

When a new version is loaded, it does not overwrite the old one. The two versions are compared, obligation by obligation, and each one is labelled as new, amended, unchanged or removed. You can see the previous wording and the new wording side by side.

Only the parts that changed are re-checked against your policies. Everything you had already settled stays settled. What you get is a short list: these obligations changed, these are the documents of yours that no longer cover them, and here is what to do about each.

Where the change is future dated, like both of the January changes, it is flagged as upcoming and kept separate from your current compliance position. You can see what is coming and plan for it, without it distorting where you stand today.

And every analysis records the instrument versions it ran against. A report produced in March still shows March's obligations when someone opens it in September. That matters more than it sounds, because the question an inspector asks is rarely "are you compliant now". It is "how did you reach that conclusion, and when".

The point

Regulatory change management is usually sold as an alert. You get told something changed.

Being told is the easy part. The value is in knowing, the same day, which of your own documents just stopped being good enough, and having a record of what you did about it.