FAQs on the Notice on Business Conduct Requirements for Corporate Finance Advisers

The Monetary Authority of Singapore, MAS, has published a revised version of its FAQs on the Notice on Business Conduct Requirements for Corporate Finance Advisers. The frequently asked questions specifically provide clarifications and examples of MAS‘ expectations as regards the management of conflicts of interest, internal control and governance, and customer due diligence of firms and individuals engaged in the provision of corporate finance advisory services.
This latest revised version contains an update to question 24A and related answer which now read as follows – as quoted:
Q24A – page 26: In the conduct of an IPO, RTO or business combination by a SPAC, are ‘comfort letters’ (e.g. in the style of a US 10-b-5) issued by third party service providers required? Should CF advisers rely on comfort letters provided by third party service providers in discharging their due diligence obligations under the CF Notice?
A comfort letter is not a requirement and the existence of such a letter, by itself, is insufficient to establish that a CF adviser has met with its due diligence obligations in the CF Notice. Undue weight should not be placed on such a letter, which may give rise to concerns that a CF adviser has over-relied on the third party service provider during the due diligence process. The CF adviser remains responsible for meeting all due diligence obligations under the CF Notice.