Consultation Paper on Draft Notices on the Competency Requirements for Representatives Conducting Regulated Activities under the Financial Advisers Act and Securities and Futures Act

Following a consultation (P006 – 2020) in 2000 on proposed amendments to the Capital Markets and Financial Advisory Services Examinations (CMFAS Examination) as set out in Notice FAA-N13 and Notice SFA 04-N09 which themselves outline the entry, examination, and continuing education requirements of representatives authorized under the Financial Advisers Act 2001 and the Securities and Futures Act 2001, the Monetary Authority of Singapore (MAS) has published a corresponding consultation response paper.
In this paper, MAS briefly summarizes the feedback it has received to its consultation and describes any amendments it has made to the drafted text in view of the responses.
Overall, so MAS, respondents were highly positive about the proposed changes which involved the introduction of new ethics and skills content in the newly formed rules, ethics and skills (RES) module, the tailoring of the RES module to suit the requirements of various traders, and the introduction of the option to „take new combined product knowledge modules“. Most respondents only sought clarifications, and very few others proposed to delay the deadline for the upcoming competence requirements or to exempt various financial market participants from financial examination or individual module obligations altogether.
Taking into account the feedback it has received to its consultation, MAS has made the following changes to the draft version:
– MAS has updated the revised SFA Notice to provide individuals appointed as dealing representatives of LFMCs with the flexibility to „pass either RES3 or the RES modules for dealing in CMPs“;
– MAS has also updated the revised SFA Notice to provide a grandfathering exemption for representatives of an institution’s „s100(2) unit“ (a unit dealing with high net worth individuals only) that have not taken the CACS exam and updated the FAA Notice to provide an exemption from the minimum academic requirements for such units;
– MAS has also revised the SFA Notice to „exempt representatives who serve only AIs, IIs and/or EIs from the CPD requirements“;
– MAS has modified the FAA Notice to provide alternative options and recognition of training hours of appointed representatives that are enrolled in or have engaged in the Institute of Banking & Finance (IBF) certification.
Finally, MAS has delayed the implementation date to April 1, 2024 and will issue revised FAQs in due course to provide clarifications on the new CMFAS examination requirements.
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In view of the upcoming changes, MAS has also republished the existing Notice FAA-N13 and Notice SFA 04-N09 as they apply before the changes take effect.