"Who manages the money" has two answers. When you buy an ILP, your premiums buy units in sub-funds set up by the insurer, and the counterparty is the insurer. When you invest through an independent fund platform (for example, a platform such as iFAST that serves financial advisers and individual investors), you hold unit trusts or other securities directly, and the platform handles dealing, custody arrangements and statements. The two routes may invest in the same kind of assets run by the same fund manager, but they differ in legal structure, layers of charges and protection. This guide covers only public rules and mechanics and does not recommend any platform, insurer or fund.

Two routes: insurer sub-funds and funds on a platform

Take a sum of money intended for long-term investment. The money flows along the two routes as follows:

  1. Insurer sub-fund route: money → insurer (premium charge deducted) → units bought in an ILP sub-fund → the sub-fund is invested by the insurer or an external fund manager → insurance charges and policy fees are deducted from units → the policyholder has a contractual right based on the value of the units.
  2. Independent platform route: money → platform account (usually held by a custodian in a nominee account) → unit trusts, ETFs, bonds and so on are bought → the fund is invested by a fund management company and the assets held by a trustee or custodian → the platform issues holdings and transaction statements for the account.

The most common link between the two routes is that many ILP sub-funds themselves invest in one or more unit trusts, so the same underlying fund may be held indirectly through an insurer's sub-fund and bought directly on a platform; only the outer "wrapper" differs.

Insurer sub-fund ranges: structure and rules

The LIA guide explains that a sub-fund pools policyholders' premiums and invests them in a basket of assets according to an investment objective, and may be managed by the insurer or an external fund manager. MAS Notice 307 sets a number of requirements for sub-funds:

  • Investment restrictions: sub-funds should comply with the core investment guidelines and borrowing limits of the Code on Collective Investment Schemes (paragraph 51, a non-mandatory standard).
  • Valuation and pricing: the unit price equals net asset value divided by the number of units (paragraph 12), with valuation every business day (paragraph 75); under the LIA industry standard, single pricing applies from 8 October 2021.
  • Documents and reports: each sub-fund must have a Product Highlights Sheet (PHS, paragraph 33), and semi-annual and audited annual reports must be sent (paragraph 36); time limits for paying redemption proceeds are covered in How ILPs are regulated.

The size of a sub-fund range varies by insurer. One insurer's public fund price page, for example, listed about 40 funds or portfolios as at 22 October 2026, including dynamic portfolios, lifecycle portfolios, a cash fund and a physical gold fund (Great Eastern Life GreatLink fund prices page); for other insurers, refer to the fund lists on their own websites.

From a protection standpoint, the part of an ILP's benefits linked directly to sub-fund net asset value is not a guaranteed benefit and is outside the Policy Owners' Protection (PPF) Scheme (SDIC).

Independent fund platforms: what platforms such as iFAST do

An independent fund platform is an intermediary layer linking fund houses, financial advisers and investors. It usually takes one of two forms: a B2B platform for financial advisers (advisers open accounts, place orders and manage portfolios for clients on the platform) and a B2C platform that investors operate themselves. Platforms typically offer a wrap account, holding unit trusts, ETFs, shares, bonds and cash in one account, and accept several sources of payment such as cash, SRS and CPF, subject to the platform's terms.

Scale as a reference point: in its SGX announcement of 12 February 2026, iFAST Group disclosed that its assets under administration (AUA, the assets the platform holds in trust or custody, as distinct from assets under management, AUM) were S$31.98 billion as at 31 December 2025, up 27.9% year on year, with Singapore remaining the main contributing market. This is a group figure that includes Hong Kong, Malaysia, mainland China and bank deposits, and should not be read as the size of a Singapore ILP or adviser platform. The type of licence a platform holds can be checked on the MAS Financial Institutions Directory.

CPFIS Investment Administrators: to buy unit trusts through a platform with CPF, the platform must be included on the CPFIS list of Investment Administrators. The inclusion criteria published by the CPF Board (updated 7 June 2024) include holding the relevant MAS licence, having investors' assets held by a custodian in nominee accounts with separate records for each investor, and offering products from different providers.

The status of unit trusts: MoneySense explains that local and overseas funds offered to retail investors are regulated as collective investment schemes; those constituted locally are authorised schemes and those constituted overseas are recognised schemes, and both can be looked up on MAS's OPERA system.

Comparison: the key differences between the two routes

Aspect Insurer ILP sub-fund Unit trust / wrap account on a platform
Legal form Insurance contract plus a sub-fund set up by the insurer Units in a collective investment scheme, held through the platform's nominee account
Counterparty Insurer Fund management company (through the platform and custodian)
What you hold A contractual right against the insurer, valued by the units allocated Fund units (held in a nominee name, recorded separately for each investor)
Who makes investment decisions The sub-fund manager (insurer or external appointee) The fund manager; portfolio allocation is decided by the investor and adviser
Protection component Life cover included; insurance charges rise with age None; insurance bought separately
Layers of charges Premium charge, insurance charges, policy fee, sub-fund management fee (with separate charges for any underlying fund) Sales charge, platform or wrap fee, fund expense ratio
Protection arrangements The PPF Scheme covers only guaranteed benefits; the NAV-linked part is excluded Outside the PPF Scheme; relies on asset segregation and trustee / custody arrangements
Statements Policyholder statement (yearly or monthly), sub-fund semi-annual and annual reports Platform holdings and transaction statements, fund reports
Switching Only between that insurer's sub-funds, with a limit on free switches Between products from different fund houses on the platform, with fees as set by the platform
Cost of exit Possible surrender charges, or high premium charges already paid, in the early years Possible redemption charges; usually no policy-level surrender charge

The MoneySense guide to unit trust fees (updated 15 July 2026) gives public reference ranges for the platform route: sales charges are usually 1.5% to 5% of the amount invested, expense ratios usually 1.0% to 2.5% of the fund's net asset value, platform fees around 0 to 0.3% a year and wrap fees around 1% a year. Actual fees are as stated in the platform and fund documents.

Common ways of combining the two

The two routes are not either-or. In practice, the following combinations are common:

  1. Separating protection and investment: term insurance for cover, and unit trusts or ETFs on a platform for long-term investing; the layers of charges are clear and exit is flexible, but you have to maintain investment discipline yourself.
  2. Protection ILP plus platform investing: a protection ILP provides the sum assured and keeps some money invested, while money beyond the protection need sits on a platform.
  3. ILP as the main investment vehicle: suits people who value "managing protection and investment in one contract" and accept a longer holding period and multiple layers of charges.
  4. CPF and SRS money: both routes can be used, but there are extra restrictions on insurance products; see Buying an ILP with CPF or SRS.

The adviser's role on both routes and the public rules

On either route, most retail investors buy on the advice of a licensed representative: a Customer Knowledge Assessment (CKA) is required before buying an ILP or a fund that is an unlisted Specified Investment Product (since 1 January 2012), and the representative must have a reasonable basis for the recommendation through a financial needs analysis (LIA guide). An ILP's Policy Illustration shows distribution costs; for unit trusts, these appear in items such as the sales charge and wrap fee.

Before signing, check item by item:

  1. Is this money going into an insurer's sub-fund or a fund on a platform? Who is the counterparty?
  2. Who is the sub-fund's manager? Does it invest in another unit trust? How much does the underlying fund charge separately?
  3. How many layers of charges are there in a year? Which document sets each out, and is there a contractual maximum?
  4. How wide is the switching range? How many free switches are there each year?
  5. What does it cost to exit early?
  6. Which parts are covered by the PPF Scheme and which are not?

If you would like this interpreted against your own circumstances, you can register your request through the contact details on this site.

Sources and dates

  1. MAS Notice 307 Investment-Linked Policies (last revised 28 June 2021) — Monetary Authority of Singapore (MAS) · 2021-06-28
  2. iFAST Corp: FY2025 Net Profit Up 50.1% YoY to S$100.01 million (SGX announcement) — iFAST Corporation Ltd. · 2026-02-12
  3. Unit trusts: Guide to pricing and fees — MoneySense (MAS) · 2026-07-15
  4. What are the criteria for inclusion as an Investment Administrator under the CPF Investment Scheme (CPFIS)? — CPF Board · 2024-06-07
  5. PPF Entitlement — Singapore Deposit Insurance Corporation (SDIC) · no update date shown (accessed 2026-10-23)
  6. GreatLink Funds Prices — Great Eastern Life · no update date shown (accessed 2026-10-22)
  7. Understanding unit trusts — MoneySense (MAS) · 2026-07-02