The Monetary Authority of Singapore (MAS) today released its response to the feedback on proposals to enhance the requirements for Product Highlights Sheets (PHS) and streamline the distribution safeguards for complex products.
2 Digitalisation has increased retail investors’ access to information and reshaped how they are choosing to access investments. To provide investors the flexibility to opt in or out of financial advice on complex products, MAS will proceed with the proposals to remove the mandatory financial advice requirement for complex products except for investors who require additional protection. MAS will also proceed with the proposals to enhance the PHS disclosure requirements and other distribution safeguards that financial institutions must provide to enable investors to make informed decisions.
3 The enhanced PHS disclosures will more clearly highlight the key features and risks of complex products to help investors better understand the product. This will be accompanied by the introduction of pre-transaction alerts for complex products to remind investors to carefully understand the product to assess suitability for their financial circumstances or seek financial advice before investing. Stronger safeguards will remain in place for investors who require additional protection
4 Respondents were broadly supportive of the proposals. They welcomed the shift towards a more disclosure-based regime, and the streamlining of the customer journey for self-directed investors. MAS has incorporated feedback from the consultation into the finalised PHS templates and distribution safeguards for complex products. Details are set out below.
Enhanced Product Highlights Sheet (PHS)
5 MAS will proceed with the proposed PHS enhancements, with further refinements that include clearer labelling for complex products. Investment-Linked Policies (ILPs) will now require a PHS and be classified as complex products. This reflects the structural complexity of ILPs and their combination of insurance and investment features.
Streamlined and Enhanced Distribution Safeguards for Complex Products
6 MAS will proceed to introduce pre-transaction alerts and make financial advice optional for complex products
a. Investors who fail the Customer Knowledge Assessment (CKA) must be alerted that complex products may not be suitable for them.
b. All investors will be alerted that a product is complex, with an accompanying reminder to review product documents carefully, and to take a learning module on complex products or seek financial advice where needed.
c. Investors will have the option of receiving a streamlined version of the pre-transaction alerts for subsequent transactions within the month, if they have traded in complex products during this period.
7 Mr Lim Tuang Lee, Assistant Managing Director (Capital Markets), MAS, said: “These measures foster an accessible and dynamic market. They acknowledge the growing sophistication of investors who can self-direct and analyse their own investments while catering to the needs of selected investors that may continue to require additional support and safeguards.”
8 The detailed response to the consultation feedback and final measures are available on the MAS website here. Legislative amendments to implement the changes will be consulted on at a later date.
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[1] Complex products are products with more complicated features. Examples of complex products include structured notes, derivatives, and following the implementation of the proposals, Investment-Linked Policies (ILPs). For more information on MAS’ earlier consultation, please refer to: MAS Proposes to Enhance Product Highlights Sheets and Streamline Framework for Complex Products .
[2] This refers to “Selected Clients” as defined in the Notice on Recommendations on Investment Products (FAA-N16), i.e., customers of financial institutions who meet any two of the following criteria: (a) Is 62 years of age or older; (b) Is not proficient in spoken or written English; (c) Has below GCE “O” or “N” level certifications, or equivalent academic qualifications.
[3] “Selected Clients” must receive financial advice before investing in complex products, unless they pass the Customer Knowledge Assessment and opt out of the mandatory financial advice safeguard.
[4] Having considered user experience and other feedback on the proposed introduction of Product Knowledge Assessment (PKA) as an alternative to CKA, MAS will not proceed with the proposal and will work with the administrators of learning modules on complex products to enhance these modules for investor education and knowledge evaluation (e.g. Association of Banks in Singapore, Securities Association of Singapore, and Singapore Exchange).
