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.
Compliance impact
This is a binding conduct-reporting change with broad impact across Singapore financial advisers, capital-markets firms, insurance brokers and direct insurers. Failure to identify reasonable grounds promptly, report within 21 calendar days, provide required copies, submit investigation or update reports, or retain supporting records could lead to supervisory engagement and concerns about the firm’s governance, controls and fitness-and-propriety oversight.