Chapter 3 · quick-revision digest · narrative, key figures & core facts
Chapter 3 covers the first three MAS Notices: FAA-N16 on recommendations on investment products, FAA-N03 on information to clients and product disclosure, and FAA-N11 on dual currency investments. FAA-N16 (in force since 1 January 2012) turns the reasonable-basis duty into a working procedure: collect the Know Your Client information, analyse the client's needs, and document the basis of every recommendation. Its centrepiece is a pair of gatekeeping assessments โ the Customer Knowledge Assessment (CKA) before a client transacts in unlisted Specified Investment Products, and the Customer Account Review (CAR) before trading listed SIP-derivatives. The two are deliberate look-alikes with different criteria, different validity periods, and their own escalation path: a client who fails but insists on trading needs senior-management sign-off. Overseas-listed products are SIPs by default and carry a prescribed risk warning (since 8 October 2018).
FAA-N03 sets the disclosure discipline. Every statement to a client must meet three general standards โ Clear, Adequate, and Not False or Misleading โ and the Notice prescribes the categories of product information a financial adviser must disclose for a designated investment product: nature and objective, provider, rights, commitment, benefits, risks, pricing, fees, reports and exit options. Around this sit rules on disclosing the adviser's own status and remuneration, conflicts of interest, performance illustrations and marketing material.
FAA-N11 (since 1 March 2006) targets dual currency investments: the client must understand that the issuer, not the investor, holds the option to repay in the base or the alternate currency, and prescribed risk warnings must appear in all marketing and disclosure documents. Contravening any Notice is an offence, so the three Notices carry real teeth behind their procedural detail.
| Item | Value | Type | Source |
|---|---|---|---|
| Validity period of a Customer Knowledge Assessment | 1 year | Threshold | p. 3A-10 |
| Validity period of a Customer Account Review | 3 years | Threshold | p. 3A-15, 3A-16 |
| Transaction-frequency criterion for CKA and CAR | 6 transactions | Threshold | p. 3A-25, 3A-26 |
| Work-experience criterion for CKA and CAR | 3 years | Threshold | p. 3A-26 |
| Past-performance disclosure period of not less than one year | 1 year | Threshold | p. 3B-15, 3B-16 |
| Execution-related advice dealer exception and annual profile update | 1 year | Deadline | p. 3A-7 |
| Retention of overseas-listed acknowledgement records | 5 years | Deadline | p. 3A-22 |
| Documents kept up to date and reviewed at least annually | 1 year | Deadline | p. 3B-4 |
| Oral disclosure of CIS performance and the 3-month rule | 3 months | Deadline | p. 3B-12 |
| Penalty for contravening a MAS Notice | 25000 SGD | Penalty | p. 3A-24, 3B-13 |
| Event | Date | Source |
|---|---|---|
| FAA-N16 legal basis and commencement | 2012-01-01 | p. 3A-2 |
| Risk warning statement for overseas-listed products | 2018-10-08 | p. 3A-22 |
| FAA-N11 legal basis and commencement | 2006-03-01 | p. 3C-2, 3C-6 |
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