Singapore

Short Disclosure Rules in Singapore take effect from 1st October 2018. The Monetary Authority of Singapore (MAS) is the competent authority.

Any person or legal person owning a short position above the designated threshold is required to disclose the position. Reporting is on a weekly basis.

The short position threshold is the lower of:

(a) 0.2% of total issued shares in the relevant class of shares or units; or
(b) S$ 2,000,000.

Key considerations

Threshold relief is not available for funds not owned by you i.e. funds managed on behalf of third parties
Only the same class shares to be used in denominator as opposed to the total shares outstanding used in some other jurisdictions
No look through to ultimate entities (as opposed to some other jurisdictions)
For incorporated funds, generally the disclosures will be at the fund level. However, if a fund is unregistered, it should be disclosed against the ultimate owner

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