Reviewers can tell within a few pages whether a compliance manual was written by the firm or bought by it. The giveaway is usually boilerplate: policies that mention strategies you do not run and roles you do not have - my site!
A framework that passes begins with your actual business. Who are your investors, accredited or institutional, or do you hope to serve a wider group? What do you invest in? How many people sit in the office? Every policy should answer to those facts. If your fund trades listed equities only, a lengthy section on illiquid asset valuation tells the reader you copied it.
Under the Securities and Futures Act, MAS looks at how you will govern yourself, so the structure matters as much as the words. Show clear lines: the board, the compliance function, the people who make investment decisions, and where they are kept apart. Independence is the quiet theme running through everything. The person monitoring trades should not be the person placing them.
Then comes the evidence of life. Describe how a breach would be spotted, who logs it, what happens next, and who tells the regulator. Include things like personal trading rules for staff, gift and entertainment limits, complaint handling, record retention and anti-money-laundering checks on investors. Each one can be short. None can be missing.
People underestimate the testing side. A compliance programme includes monitoring: what gets checked, how often, and by whom. A calendar of reviews, even a modest one, shows intent. A manual with no schedule of checks is a promise nobody has to keep.
Be honest about outsourcing too. If you use an administrator, a custodian or an external compliance provider, say what they do and what you still own. Responsibility stays with you whatever you hand off, and MAS knows it.
Finally, read the whole thing aloud as if you were a sceptical examiner. Where does it say "appropriate" without saying what that means? Where does it say "regularly" without a frequency? Fix those lines first, since vague words are where applications go to get follow-up questions.