Country Manual Products
We would like to inform you that BRP has reviewed and updated the BEHAVIOUR TEMPLATE (4th Edition 2020; minor amendment of the structure), the DEFINITIONS & CONCEPTS and the REGULATORY OVERVIEW for the following COUNTRY MANUAL PRODUCTS:
SINGAPORE (SG)
Please note the following material changes regarding the above-mentioned jurisdiction:
- The specific “Private Placement Exemption CIS” relating to “Other Investors” (Accredited Investors) has been updated and amended, based on discussions with our local counsel. As a result – and based on a conservative interpretation/approach – in such constellations, “unregistered CIS” require additionally to be qualified as a so called “restricted CIS” (the manual however highlights the fact that the applicability of this requirement in cross-border constellations is unclear, that the practices in the market diverge and that no formal guidance from the MAS is available). This new requirement is alternative to the other exemptions, which remain unchanged (i.a. “small personal offers” and/or offers addressed to the maximum of 50 investors). The Behaviour Template now provides the answer “Grey zone/YES: Private Placement Exemption CIS” (instead of “YES”) in cross-border constellations (remote).
- For consistency purposes and in alignment to the CM Private Banking (CM PB) any activity (except the provision of macroeconomic information) towards Retail Investors and Other Investors taking place on Singapore territory (at target) is no longer permitted. Accordingly, the CM Products Behaviour Template (CM P BT) now provides the answer “NO” for these scenarios.
- Also in alignment to the CM PB, the proactive provision of advice “without/outside the scope of an advisory agreement (spot advice)” towards Retail Investors and Other Investors on a cross-border basis (remote) is no longer permitted and hence, the CM P BT answers these latter scenarios with “NO”.
Should you have any questions, please do not hesitate to contact us.