MAS Information Paper Outlines Supervisory Expectations and Good Practices Concerning Market Conduct Controls for FIs in the Financial Advisory Industry

MAS Information Paper Outlines Supervisory Expectations and Good Practices Concerning Market Conduct Controls for FIs in the Financial Advisory Industry

On 26 May 2026, the Monetary Authority of Singapore (“MAS“) issued its “Information Paper on Good Practices of Market Conduct Controls in the Financial Advisory Industry” outlining its supervisory expectations and good practices observed for financial institutions (“FIs“) in the financial advisory industry, in the following areas: (i) prospecting and advertising activities; (ii) advisory and sales processes; (iii) safeguards for sales to vulnerable customers; and (iv) complaints handling processes.

FIs are expected to benchmark their policies and processes against these practices and implement enhancements, commensurate with their business and risk profile, to strengthen their control frameworks.

Prospecting and Advertising Activities

Roadshow Activities

1. Supervisory expectations: “Outcome Three” of the “Guidelines on Fair Dealing – Board and Senior Management Responsibilities for Delivering Fair Dealing Outcomes to Customers [FSG-G04]” published in May 2024 (“FDG“) sets out expectations that FIs should ensure that their representatives provide appropriate advice and recommendation to customers. This includes ensuring that their representatives do not apply aggressive or pressure sales tactics, and providing customers with sufficient time to understand the information provided and consider the recommendations made by the representatives.

2. Good practices: Good practices for roadshow activities include the following:

• • Mitigating aggressive marketing practices: FIs should reduce the risk of pressuring or harassing consumers, e.g. by requiring agency leaders and representatives who engage crowd pullers to attend mandatory training prior to each roadshow.
  • Facilitating customer feedback: FIs should enable customers to report issues and ensure that feedback is addressed promptly, e.g. by prominently displaying Quick Response (QR) codes for customers to provide on-the-spot feedback at roadshows.

Digital Advertisements 

3. Supervisory expectations: “Safeguard 4” of the “Guidelines on Standards of Conduct for Digital Advertising Activities” published on 25 September 2025 sets out expectations that FIs should monitor the digital advertising activities conducted by their digital marketers.

4. Good practices: Good practices for disseminating digital advertisements include the following:

• • Requiring disclosure of representatives’ identities: FIs should allow customers to easily verify the identities of representatives, e.g. by requiring representatives to disclose their names and representative numbers on their social media accounts and digital advertisements.
  • Ongoing monitoring of digital advertisements: FIs should ensure that marketing materials used by representatives are fair and not misleading, e.g. by: (i) requiring representatives to seek prior approval for all self-created marketing materials; (ii) requiring representatives to submit a screenshot and link to the live advertisement within three days of posting; and (iii) conducting monthly/quarterly sampling checks of representatives’ social media posts.
  • Scrutinising representatives with past complaints: FIs should conduct targeted monitoring of representatives with misconduct or complaints related to their digital advertising activities, e.g. by: (i) maintaining an inventory of such representatives’ social media accounts for enhanced monitoring, using social media listening tools; and (ii) conducting bespoke training for agencies with higher numbers of representatives with such complaints/misconduct.

Advisory and Sales Processes 

1. Supervisory expectations: “Outcome Three” of the FDG sets out expectations that FIs should: (i) develop a robust training and competency programme to ensure representatives are equipped with the necessary skills and knowledge to undertake a proper fact-find and to provide advice to customers; and (ii) ensure that their fact-find forms and risk-profiling questionnaires adequately capture all relevant information about the customer.

2. Good practices: Good practices to support representative-customer engagement during advisory and sales processes include the following:

• • Supporting non-English speaking customers: FIs should enhance system language functionalities and representatives’ language proficiencies, e.g. by: (i) ensuring that their Financial Needs Analysis (“FNA“) systems include vernacular language functionalities; and (ii) providing targeted training for representatives in vernacular languages.
  • Detecting discrepancies during FNA: FIs should ensure that there is real-time detection of such information discrepancies, e.g. by utilising validation checks that are built into FNA systems, that will alert representatives when a customer’s: (i) declared investment knowledge is inconsistent with his education, work and investment experience; or (ii) declared information in the fact-find form when making another purchase differs significantly from existing information in the system.
  • Ensuring customers understand key features and risks: FIs should strengthen customers’ product understanding and awareness, e.g. by providing concise disclosure summaries for complex products in simple language on key product features and risks.

Safeguards for Sales to Vulnerable Customers

1. Supervisory expectations: “Outcome Two” of the FDG sets out expectations that FIs should: (i) pay special attention to customers who have been identified to be more vulnerable; and (ii) take steps to identify vulnerable customers for whom certain products may not be suitable, and have robust controls and appropriate safeguards to prevent the inappropriate sale of such products to these customers. For more information on vulnerable customers, please refer to our April 2025 Legal Update titled “Financial Advisers to Enhance Transaction Safeguards for Vulnerable Retail Clients by 29 December 2025“.

2. Good practices: Good practices on additional safeguards for vulnerable customers include the following:

• • Proactively identifying vulnerable customers: FIs should proactively identify vulnerable customers to allow for more care and attention to be provided to them, e.g. by adopting broader definitions of vulnerable customers beyond MAS’ definition of Selected Clients (“SCs“). These include customers who: (i) meet any one criterion of MAS’ definition of a SC, instead of two; (ii) have experienced recent changes in their personal circumstances; or (iii) exhibit signs of vulnerability such as impaired physical or mental capabilities.
  • Supporting with additional safeguards: FIs should implement additional measures to support such customers in the sales and advisory process, e.g. by: (i) applying the same safeguards for vulnerable customers as those required for SCs under MAS regulations; and (ii) implementing additional controls, such as requiring face-to face advisory sales, pre-transaction call-backs by supervisors, etc.

Complaints Handling Processes

1. Supervisory expectations: “Outcome Five” of the FDG sets out expectations that FIs should: (i) handle customer complaints in an independent, effective and prompt manner; (ii) have a process to escalate significant complaints to the board and senior management; (ii) perform a trend analysis of complaints to seek out root causes, rectify them promptly, and identify areas of interest; and (iv) incorporate these lessons learned from complaints analysis into their policies and practices.

2. Good practices: Good practices observed on complaints handling include the following:

• • Escalating material or complex complaints: FIs should support timely resolution and consistent decision-making, e.g. by escalating specific complaints cases to senior management that require close attention or highlight control weaknesses, including complaints involving vulnerable clients, complaints with fraud allegations, and complaints where the Financial Industry Disputes Resolution Centre ruled against the FI.
  • Leveraging complaints data: FIs should facilitate the identification of themes and underlying causes to mitigate recurrence, e.g. by: (i) incorporating trends/insights from complaints data to improve market conduct controls, and from surveillance and monitoring indicators for earlier detection and escalation for investigation; and (ii) conducting regular training sessions or disseminating newsletters to share key lessons and common mistakes made by representatives from their review of complaints.

Click on the following link for more information:

• Information Paper on Good Practices of Market Conduct Controls in the Financial Advisory Industry (available on the MAS website at mas.gov.sg)