Representatives appointed by capital markets intermediaries and financial advisers to conduct regulated activities under the Securities and Futures Act (“SFA“) and Financial Advisers Act (“FAA“) (“Appointed Representatives“) are required to meet minimum academic qualifications and pass the relevant modules under the Capital Markets and Financial Advisory Services Examination (“CMFAS Examination“). The purpose of the CMFAS Examination requirement is to ensure that Appointed Representatives have a good understanding of the financial markets in which they operate and the products that they deal with.
On 1 April 2024, the CMFAS Examination requirements will be revised to:
- raise the competency of and build a culture of high ethical standards among Appointed Representatives; and
- provide more flexibility to Appointed Representatives to customise the modules under the CMFAS Examination to suit their roles.
The new CMFAS Examination requirements have been set out in the following new Notices issued by the Monetary Authority of Singapore (“MAS“) on 28 September 2023. These Notices will take effect on 1 April 2024.
- Notice SFA 04-N22 on Competency Requirements for Representatives of Holders of Capital Markets Services Licence and Exempt Financial Institutions (“SFA Notice“) which applies to Appointed Representatives of capital markets services licensees, or of banks, merchant banks, finance companies and insurers who are conducting regulated activities under the SFA.
- Notice FAA-N26 on Competency Requirements for Representatives of Financial Advisers (“FAA Notice“) which applies to Appointed Representatives of licensed financial advisers, or exempt financial advisers under the FAA.
The Institute of Banking and Finance (“IBF“) and the Singapore College of Insurance (“SCI“), which administer the CMFAS Examination, will start registrations for the new CMFAS Examination and make available the new study guides at least two months before the new CMFAS Examinations commence on 1 April 2024. Grandfathering arrangements will be put in place for certain existing Appointed Representatives as of 1 April 2024.
This Update discusses the following key aspects of the new CMFAS Examination regime:
- Content on ethics and skills will be introduced into the existing CMFAS Rules and Regulations modules to form new Rules, Ethics and Skills (“RES“) modules with the following key features:
- RES modules will contain new content on ethics and skills;
- each RES module will be customised with reference to the job roles of Appointed Representatives instead of regulated activities; and
- RES modules for Appointed Representatives trading on securities and derivatives exchanges will be streamlined and tailored.
- Appointed Representatives will be offered an option to take new combined product knowledge modules.
- Existing Appointed Representatives will be grandfathered under the new CMFAS Examination regime.
- Clarifications by MAS on CMFAS Examination requirements for Appointed Representatives of a Licensed Fund Management Company (“LFMC“) and exemptions for certain private banking representatives (“PB Representatives“).
- Refinements to continuing professional development (“CPD“) requirements for Appointed Representatives.
These changes have undergone two rounds of MAS consultation exercises from December 2016 to January 2017 and from 4 September 2020 to 5 October 2020, respectively, which sought public feedback on the proposals for enhancements to the CMFAS Examination requirements and draft Notices implementing the proposals.
For more information, click here to read the full Legal Update.
