On 29 December 2025, the Monetary Authority of Singapore (“MAS“) revised the following Notices, Guidelines and FAQs under the Financial Advisers Act (“FAA“) to implement enhanced transaction safeguards for vulnerable clients. The changes took effect on 29 December 2025.
- MAS Notice FAA-N16 Recommendations on Investment Products;
- MAS Notice FAA-N20 Requirements for the Remuneration Framework for Representatives and Supervisors (“Balanced Scorecard Framework”) and Independent Sales Audit Unit;
- MAS Guidelines on the Remuneration Framework for Representatives and Supervisors (“Balanced Scorecard Framework”), Reference Checks and Pre-Transaction Checks [FAA-G14]; and
- FAQs on the Balanced Scorecard (BSC) Framework.
Key Revisions
- Strengthening selected client (“SC”)-related protections: Strengthening the requirement to identify SCs and requiring checks and documentation of a client’s SC status as well as the making of a formal declaration that this assessment has been duly performed. SCs are retail clients who are older in age and may not have specific academic qualifications. Financial Adviser (“FA“) firms are required to undertake pre- and post-transaction safeguards for SCs to ensure that they understand the risks of their investments.
Introducing trusted individual (“TI”) qualifications and requirements: Requiring a TI, who must fulfil certain criteria to qualify as such, to be present when investment recommendations are made to SCs.
Enhancing pre-transaction call-back requirements: Mandating the types of information to be covered during a pre-transaction client call-back and requiring FA firms to audio record pre-transaction call-backs to: (i) SCs; or (ii) clients of Selected Representatives (i.e. an FA representative who has been assigned a Balanced Scorecard Grade B or worse for two consecutive calendar quarters immediately preceding the measurement quarter).
- Enhancing post-transaction checks requirements: Updating the: (i) scope of post-transaction checks performed by the Independent Sales Audit unit, including reviewing the above-mentioned recordings; (ii) guidance on document reviews performed as part of such checks; and (iii) requirements and guidance on the classification of infractions committed by FA representatives.
For more information about these changes, please refer to our April 2025 Legal Update titled “Financial Advisers to Enhance Transaction Safeguards for Vulnerable Retail Clients by 29 December 2025“.
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