Consumer Protection / Conduct in Singapore

Key dates

2026-10-29

MAS published the policy statement announcing the extension of motor vehicle financing restrictions to individual-owned PHCs.

2026-10-30 Deadline

New restrictions take effect for individual-owned PHC purchases where the sales agreement is signed on or after this date; where there is no sales agreement, they apply if the COE is obtained on or after this date.

Suggested considerations

• Compliance teams at affected lenders should update eligibility, LTV and tenure controls so that individual-owned PHCs are treated as private cars for transactions falling within the effective-date tests.
• Firms should confirm that the LTV calculation uses the full purchase price, including relevant taxes and the COE price where applicable, and that the OMV threshold is applied at $20,000.
• Lenders and finance providers should review onboarding and documentation controls to distinguish individual or sole-proprietor ownership from business-owned PHC ownership and to evidence the sales-agreement or COE date.
• Providers should assess pending applications, approvals, hire-purchase agreements and conditional sales near the 30 October 2026 transition point, including whether any transaction was restructured to avoid the new restrictions.
• Car dealers and platform operators should consider updating customer disclosures, application workflows and referral arrangements so that individual buyers are not presented with financing terms inconsistent with the new limits.
• Firms should review dealer, leasing and in-house financing products for potential regulatory perimeter or circumvention risk, particularly because the Government has indicated that it may apply equivalent restrictions to additional arrangements.
• Compliance teams may wish to monitor MAS and Government follow-up, including implementation guidance and any measures affecting in-house loans or platform-operated financing channels.
• Firms should consider controls and customer communications addressing unregulated leasing, lease-to-own or other arrangements that may be marketed as alternatives to regulated motor vehicle financing.

What changed

For an individual-owned PHC with an OMV of $20,000 or below, the maximum LTV is 70% of the purchase price, including relevant taxes and the COE price where applicable. For an OMV above $20,000, the maximum LTV is 60%; financing tenure is capped at seven years in both cases. The restrictions apply to motor vehicle loans provided by financial institutions and licensed or exempt moneylenders, and to hire-purchase and conditional sale agreements.

Key dates

2026-10-12

MAS announced the enhanced safeguards and published its response to the consultation on public prospecting activities.

Suggested considerations

• Compliance teams may wish to map all roadshows, promotional booths and other public prospecting activities against the forthcoming restriction to designated areas at commercial premises.
• Firms should consider identifying suitably qualified event supervisors, defining their responsibilities and documenting escalation and intervention procedures for representative misconduct.
• Firms should consider revising scripts and training so representatives clearly state their marketing purpose before engagement and obtain consumer consent before proceeding.
• Firms may wish to establish monitoring, sampling and management-information controls to evidence that consent was obtained and that solicitation was not persistent or otherwise inappropriate.
• Firms should review policies, representative procedures, venue approval processes, third-party arrangements and supervisory testing for continued street canvassing or door-to-door activity, which remains prohibited.
• Compliance teams may wish to track the 2027 issuance of the updated Guidelines and calculate the applicable nine-month transition period from the actual issuance date rather than from this announcement.
• Firms should consider aligning physical prospecting controls with their existing controls for digital advertising activities introduced in September 2025.

What changed

Financial institutions will be expected to conduct public prospecting only in designated areas at commercial premises. They will need to appoint suitably qualified individuals to oversee representatives’ conduct at such events. Representatives must disclose at the outset that they intend to market financial products or services and obtain the consumer’s consent before continuing the engagement. Street canvassing and door-to-door prospecting remain prohibited.

Key dates

2026-10-07

MAS published its written parliamentary reply stating that LIA’s next review of severe-stage critical illness definitions will commence in 2027 and that updated definitions will apply to new products sold.

2027-01-01

The LIA review is expected to commence during 2027; the publication does not specify an exact commencement date or impose a firm for firms to act by this date.

2025-10-01

The LIA Critical Illness Framework 2024 was required to be adopted for new products no later than this date, according to independent industry and LIA-related materials; this is relevant background rather than a new deadline created by the MAS reply.

Suggested considerations

• Compliance teams may wish to monitor the LIA’s 2027 review, consultation materials, final framework amendments, implementation dates, and any MAS communications that follow.
• Insurers should consider mapping current severe-stage definitions to the procedures and clinical severity criteria that may be affected, including identifying products whose claims triggers are particularly dependent on a named surgical procedure.
• Product governance, actuarial, underwriting, claims, legal, and compliance functions may wish to assess how alternative disease- and severity-based triggers could affect coverage scope, expected claims frequency, reserves, reinsurance, and pricing.
• Firms should consider documenting whether existing policy wordings can continue to be administered consistently with their contractual terms and should avoid treating any future framework revision as automatically applicable to in-force policies.
• Insurers developing new products should consider preparing customer disclosures explaining the relevant disease, severity, diagnostic evidence, exclusions, waiting periods, and any procedure-independent claims criteria.
• Compliance teams may wish to review product approval and change-control processes so that future LIA definition changes are reflected consistently in policy documents, benefit illustrations, sales materials, claims manuals, staff training, and complaint-handling procedures.
• Actuarial and product teams should consider reassessing premiums and claims assumptions before launching products using revised definitions, since MAS expressly notes that premiums depend on the probability of claims materialising.

What changed

No immediate statutory requirement, product withdrawal, or mandatory amendment to existing policies was introduced. LIA’s 2027 review will consider procedure-neutral or less procedure-dependent definitions for certain medical conditions, while retaining the use of procedures where they provide objective evidence of severity, recovery duration, and financial impact. Any resulting changes will apply to new products sold; existing policies remain governed by their contractual definitions and terms.

Key dates

2026-10-07

MAS published the written parliamentary reply and stated that approximately 4,000 households could face cash shortfalls under the severe stress scenario.

Suggested considerations

• Compliance and consumer-credit teams may wish to confirm that mortgage portfolios have documented processes for identifying deteriorating repayment performance and other early indicators of financial stress.
• Banks should consider reviewing whether frontline and collections staff consistently contact borrowers early, assess individual circumstances, and record the rationale for any restructuring, refinancing, forbearance, or other assistance offered.
• Mortgage lenders may wish to test whether vulnerable segments identified by the MAS stress test, including lower-income middle-aged HDB borrowers and borrowers with sizeable private-housing loan balances, are adequately represented in portfolio monitoring and scenario analysis.
• Firms should consider maintaining clear customer communications directing borrowers who anticipate repayment difficulty to contact the lender before arrears arise.
• Banks and relevant agencies may wish to review referral arrangements with HDB, Credit Counselling Singapore, and appropriate social-service agencies, including escalation and hand-off procedures.
• Risk committees may wish to retain evidence that severe interest-rate, income-reduction, unemployment, and liquidity-buffer scenarios are considered in mortgage portfolio risk management, while distinguishing scenario-based vulnerabilities from actual current borrower distress.
• Firms should avoid describing the approximately 4,000-household figure as a forecast of current arrears or as an individually identified list of affected customers.

What changed

No binding regulatory requirement, threshold, reporting obligation, or enforcement measure was introduced by this parliamentary reply. MAS confirmed that financial institutions monitor repayment performance and engage borrowers showing signs of financial stress, with assistance tailored to individual circumstances. HDB-financed borrowers may approach HDB for restructuring discussions, bank-financed borrowers may approach their banks, and borrowers already experiencing debt repayment difficulties may seek counselling and debt-management guidance from Credit Counselling Singapore.

Key dates

2025-12-30

MAS issued the revised Notices FAA-N27, 508 and SFA 04-N24 and published its response to feedback.

2026-08-24

MAS published the circular and FAQs explaining the revised misconduct-reporting requirements and the discontinuation of the existing system.

2027-01-01 Deadline

The revised Notices FAA-N27, 508 and SFA 04-N24 take effect; the existing Notices FAA-N14, 504 and SFA 04-N11 are cancelled; and the existing misconduct reporting system is discontinued.

2027-01-22 Deadline

Default deadline for reporting qualifying pre-2027 misconduct matters that were not reported under the cancelled Notice, calculated as 21 calendar days after 1 January 2027, unless MAS permits a longer period in writing.

Suggested considerations

• Compliance teams may wish to map existing misconduct, incident, whistleblowing, investigation, HR and police-referral processes to the revised definition and categories of reportable misconduct.
• Firms should consider establishing a documented escalation test for when reasonable grounds to believe misconduct occurred arise, rather than waiting for a final investigation finding, and configuring workflow controls around the 21-calendar-day initial-reporting deadline.
• Firms may wish to obtain and operationalise the prescribed misconduct-report, investigation-report and update-report formats before the existing system is discontinued.
• Internal investigation procedures should be reviewed to ensure that the prescribed investigation information, supporting evidence, investigator assessment, corrective action and appeal information can be produced concurrently with the initial MAS report where an investigation has commenced.
• Police-report handling should be updated so that available police reports and required accompanying details are captured and submitted with the misconduct report, with subsequent police or criminal-proceeding developments tracked for update reporting.
• Firms should consider controls for providing representatives with copies of initial misconduct reports and subsequent updates within the prescribed timelines, including appropriate treatment of former representatives and confidentiality or privilege issues.
• A transitional review of open matters may be appropriate to identify cases where reasonable grounds arose before 1 January 2027 but no report was filed under the cancelled Notice; those matters may need to be reported by 22 January 2027, subject to any written extension from MAS.
• Record-retention policies, case-management systems and management information should be tested against the minimum five-year retention requirement and the requirement that electronic records remain accessible, retrievable and readable.

What changed

From 1 January 2027, Notices FAA-N27, 508 and SFA 04-N24 replace and cancel the existing Notices FAA-N14, 504 and SFA 04-N11. The initial misconduct report must generally be submitted within 21 calendar days after the firm has reasonable grounds to believe that reportable misconduct was committed or is likely to have been committed; a conclusive investigation finding is not required before reporting.

Key dates

23 August 2018

– Initial version of CMI 27/2018 “Controls and Disclosures to be Implemented by Licensed Securities-Based Crowdfunding Operators” published by MAS

08 October 2018

– MAS publishes FAQs on Lending-based Crowdfunding, clarifying licensing and prospectus requirements and interacting with SCF-related guidance

05 March 2021

– Updated version of CMI 27/2018 and Annex A / A1 / A2 for issuer default notification uploaded, refining default reporting and controls expected of SCF operators

21 January 2025

– Revision of Guidelines on Criteria for the Grant of a Capital Markets Services Licence (SFA 04-G01), which interact with licensing expectations for SCF operators

14 July 2026

– Last revised date of circular CMI 27/2018, signalling the most recent MAS expectations on controls and disclosures for licensed SCF operators

Suggested considerations

• Review existing issuer due diligence policies and procedures and update them to align with MAS’s expectations on structured checks, documentation, and investor disclosure of due diligence scope for all SCF offers.
• Implement a formal policy prohibiting the use of new loans to repay existing overdue loans, except where legitimate reasons exist; define those reasons, approval thresholds and documentation requirements for exceptions.
• Enhance lending workflows to ensure that, when new loans are extended to borrowers with outstanding loans, the platform system automatically collates and presents total outstanding exposure and the rationale for the new loan to investors in pre-investment disclosures.
• Develop and approve a detailed issuer default management framework that defines escalation triggers, recovery options, decision criteria, investor communication templates, and record-keeping requirements.
• Update investor terms and conditions and consent mechanisms so that investors explicitly agree to any potential recovery-related costs, with clear fee schedules and scenarios disclosed before costs are incurred.

What changed

• - Licensed SCF operators must implement structured due diligence checks on issuers, including clear policies on information to be obtained, risk assessment criteria and documentation standards, and...
• Lending-based SCF operators are generally prohibited from allowing a borrower to take up a new loan to repay an existing overdue loan, unless there are legitimate, documented reasons to extend a new...
• Where a lending-based SCF operator does extend a new loan to a borrower with outstanding loans, it must disclose the borrower’s total outstanding loans and the reasons for extending the new loan so...
• SCF operators must establish formal policies and procedures for issuer default management, documenting circumstances under which the operator will pursue various recovery options (e.g.
• Operators must disclose to investors the different recovery options and associated costs and must seek and obtain investors’ consent before incurring any recovery-related costs that will be borne by...

Key dates

2022-04-19

MAS opened Consultation P002-2022 on revised misconduct-reporting Notices.

2022-05-20

Consultation P002-2022 closed.

2025-12-30

MAS issued the consultation response and Revised Notices FAA-N27, Notice 508 and SFA 04-N24.

2026-06-30

MAS targeted the second quarter of 2026 for sharing finalised misconduct and investigation-report templates; the source does not specify a precise day.

2027-01-01 Deadline

The Revised Notices take effect and affected firms must comply with the revised misconduct-reporting framework.

Suggested considerations

• Firms should map their representative and broking-staff populations, regulated activities and product lines to the applicable Notice, including the separate FAA and IA reporting treatment where conduct involves both a designated investment product and a long-term accident and health policy.
• Compliance teams may wish to update misconduct taxonomies and escalation criteria to cover Part 12 SFA market-conduct breaches, fraud, dishonesty, illegal monetary gains, client detriment, gross negligence, inappropriate advice, misrepresentation and inadequate disclosure, while documenting how non-reportable internal-policy breaches are distinguished from reportable underlying conduct.
• Firms should design procedures that identify when reasonable grounds arise and start the 21-calendar-day reporting clock without waiting for conclusive findings of culpability.
• Firms should establish decision trees for simultaneous misconduct and investigation reports, later investigation reports, update reports, police-report assessments and developments received from law enforcement or public sources.
• Firms should implement controls to provide reports and updates to current and former representatives, including identity verification, secure transmission, reasonable attempts using last-known contact details, acknowledgement or mailing evidence, and documented exceptions where disclosure could prejudice an investigation.
• Firms should review disciplinary frameworks, proportionality factors, fine calibration, appeal processes and governance to evidence a fair and transparent assessment of severity and client impact.
• Firms should enhance record-retention procedures to preserve relevant investigation, reporting, representative-notification and submission records in accessible and retrievable form for at least five years.
• Firms should monitor MAS implementation materials and final reporting templates, which MAS targeted to publish by the second quarter of 2026, and test operational readiness before the effective date.

What changed

The revised instruments are Notice FAA-N27 under the Financial Advisers Act 2001, Notice 508 under the Insurance Act 1966, and Notice SFA 04-N24 under the Securities and Futures Act 2001. A firm must generally submit a misconduct report within 21 calendar days after it has reasonable grounds to believe that misconduct was committed; conclusive proof of culpability is not required.

Key dates

29 September 2025

- Publication and issuance of ID 11/25 amendments to MAS Notice 321

1 October 2025

- Effective date for Notice 321 (Amendments) 2025

At least 1 month before launch

- MAS approval submission for industry-new DPI features; notification for insurer-new features

Within 7 working days after launch

- Notification for no-new-features DPIs

Suggested considerations

• Review and update DPI manufacturing processes to comply with standardized features in Appendix A of Notice 321, ensuring premiums ≤ non-DPI equivalents and benefits ≥ equivalents.
• Implement streamlined filing: Seek MAS approval for novel products (1-month lead), notify for insurer-novel or standard products as specified.
• For distribution: Deploy safeguards (affordability checks, info disclosure), non-advisory channels, and client query mechanisms (phone/email helplines).
• Obtain MAS written approval before offering new/re-priced DPIs; adhere to any specified launch dates.
• Update internal policies for pricing (no negating savings via margins), naming ("DIRECT" prefix), and risk assumptions matching non-DPIs.

What changed

• The amendments primarily streamline approval processes for DPI products under Notice 321 and related Notice 302:
• For new or re-priced DPIs with features entirely new to Singapore’s life insurance industry, insurers must seek MAS approval at least one month before launch.
• For DPIs with features new only to the insurer, notify MAS at least one month prior to launch.
• DPIs with no new features require notification within seven working days after launch. These changes ease prior stringent requirements while upholding core DPI mandates: standardized products (term...