In this guide · 8 sections
- 01Why fund websites have an accredited investor gate
- 02Who counts as an accredited investor
- 03What goes on the public site and what goes behind the gate
- 04How to build the investor-type confirmation
- 05Investor portals and data rooms: security basics
- 06Impersonation: protect investors from fake fund sites
- 07Do it yourself or get help?
- 08Frequently asked questions
Short answer
Funds offered only to accredited and institutional investors rely on SFA exemptions that require the offer not to be accompanied by an advertisement calling attention to it. So fund sites keep public pages general, put fund details behind an investor-type check and documents in a login-protected portal.
Why fund websites have an accredited investor gate
Most small and mid-sized Singapore fund managers run funds that are not authorised for retail sale. They are offered under SFA exemptions for institutional investors (section 304) or for accredited investors and other relevant persons (section 305, "restricted schemes"). MAS's Offers of Collective Investment Schemes page says these exempted offers are subject to conditions, "e.g., no advertising".
The wording in section 305 of the SFA is specific. Condition (3)(a) is that "the offer is not accompanied by an advertisement making an offer or calling attention to the offer or intended offer". The Act defines advertisement broadly, including written communications and communications by "other medium of communication", which covers a website. An information memorandum prepared for relevant persons is excluded.
Who counts as an accredited investor
The gate usually asks visitors to confirm they are an accredited or institutional investor. For individuals, section 4A of the SFA sets three alternative tests:
| Test | Threshold |
|---|---|
| Net personal assets | More than S$2 million, with the primary residence counting for at most S$1 million (net of any secured loan) |
| Net financial assets | More than S$1 million, net of related liabilities |
| Income | At least S$300,000 in the preceding 12 months |
Since the 2018 amendments, eligible individuals must also opt in to be treated as accredited investors by the firm. A website checkbox does not do this. It is a filter that tells visitors the content is not for the general public; the firm's onboarding and opt-in process does the real checking.
What goes on the public site and what goes behind the gate
The usual pattern separates information about the firm from information about any fund offer. A typical split:
| Public pages | Behind the investor gate | Behind a login only |
|---|---|---|
| Firm name, licence type, team, office address | Strategy descriptions in general terms | Information memorandum and fund documents |
| Contact details and how to enquire | Firm-level insights and commentary | Performance reports and factsheets |
| Privacy policy, terms, legal disclaimers | Fund names and structure, if your lawyers allow | Subscription forms, capital calls, investor statements |
| Careers and news about the firm | Data room for prospective investors |
Avoid public pages, social posts or paid ads that describe a fund's terms, performance or how to invest. Check search results too: if gated pages are indexed by Google, their content can appear in search snippets to anyone. Use noindex on gated pages and keep documents out of public folders.
How to build the investor-type confirmation
A good gate is simple, clear and consistent. Typical steps a developer would implement:
Ask the visitor's investor type and location
Offer clear choices, such as accredited investor, institutional investor, or neither, and the country they are in. Visitors who choose neither see only the general public pages.
Show the disclaimer before content
Display your lawyer-approved disclaimer and require an active click to accept. Do not pre-tick the box.
Remember the choice for a limited time
Store the confirmation in a cookie for a session or a set number of days, then ask again. Mention the cookie in your privacy and cookie notice.
Block search engines and direct links
Gated pages should not be indexed, and deep links should redirect to the gate first.
Log acceptances
Record date, time and the option selected, without collecting more personal data than needed. It helps show the gate worked as designed.
Investor portals and data rooms: security basics
The gate keeps casual visitors out of marketing pages. Fund documents and investor data need real access control, because they contain personal data and confidential information. Treat the portal or data room as a system holding customer information:
Investor portal security checklist
If your firm is MAS-licensed, the Cyber Hygiene Notice requires MFA for accounts on systems used to access customer information over the internet; see our MAS TRM checklist for small FA and fund firms. For hosting choices and costs, see our web hosting guide.
Impersonation: protect investors from fake fund sites
Investment scams often copy real fund managers' names, logos and staff profiles. Make it easy for investors to check you are genuine:
- Keep your firm name and licence details consistent with MAS's Financial Institutions Directory, which investors can search.
- State on the site that you never ask for transfers to personal accounts, and list your official domains and contact channels.
- Set up SPF, DKIM and DMARC on your domain so criminals cannot easily send email as you.
- Watch for lookalike domains and fake social profiles, and act quickly. Our lookalike domain takedown guide covers the steps.
MAS also maintains an Investor Alert List of unregulated entities that may be wrongly perceived as licensed. It is worth checking periodically for names similar to yours.
Do it yourself or get help?
Many fund websites are built on standard platforms, and the gate itself is a small piece of development. The parts that need care are the content split (with your lawyers), keeping gated pages out of search, and securing the portal or data room.
We build fund and family office sites as a Business Website package (S$1,490), including a configurable investor-type gate and noindex rules, and harden existing sites with Website Security Hardening (S$290). Legal wording and regulatory positions stay with your lawyers.
Frequently asked questions
Funds offered only to accredited or institutional investors rely on Securities and Futures Act exemptions. For restricted schemes, section 305 requires that the offer is not accompanied by an advertisement making or calling attention to the offer. Fund websites therefore restrict fund information to visitors who confirm they are not retail investors.
No. A checkbox only filters casual visitors. Under the SFA, an individual must meet one of the accredited investor tests and opt in to be treated as one, which the firm handles during onboarding with supporting documents. The website gate should be treated as one layer, with real checks done before any investment.
Under SFA section 4A, an individual qualifies with net personal assets above S$2 million (the primary residence counts for at most S$1 million), net financial assets above S$1 million, or income of at least S$300,000 in the preceding 12 months. They must also opt in to accredited investor status.
A firm can generally publish information about itself, but advertisements making or calling attention to an offer of a restricted scheme relying on the section 305 exemption conflict with the conditions of that exemption. Check any post, ad or newsletter that mentions a fund with your lawyers before publishing.
No. Information memoranda, factsheets, performance reports and investor statements should sit in a login-protected investor portal or data room, not in public folders where search engines or anyone with a link can find them. Use named accounts, MFA, watermarking and access logs.