Singapore – CM P

Update BRP Country Manual Products

Singapore

Definitions & Concepts, Regulatory Overview and Behaviour Template

The Country Manual (CM) has been reviewed to ensure that the content of all the documents remain accurate and up to date.

Material changes

The provision of investment research and financial analysis documents/reports in relation to specific companies is generally not deemed distribution in Singapore and does not trigger any product registration or documentation requirements if performed in compliance with the following marketing restrictions:

• The published information should not identify itself as being particularly relevant to local investors;

• No advertisement or published information should be referred to in, or directly accessible from, any source that is intended for local investors;

There is a prominent disclaimer stating that the published information is made to or directed at persons outside Singapore or may be acted upon only by persons outside Singapore.

In alignment with the CM Private Banking (CM PB), the provision of advisory services as well as any marketing activities onshore in Singapore (at target) are only permitted on an occasional basis towards Professional Investors. Accordingly, the CM Products Behaviour Template (CM P BT) therefore now provides the answer “Grey zone/YES – On an occasional basis” for the relevant onshore scenarios.

In addition, it is now emphasised that a “Product Highlights Sheet” only needs to be provided to a prospective investor in relation to locally registered financial products.

Non-material changes

Some comments and content have been slightly reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, May 1^st, 2025