Outline

The financial services industry has shifted and repositioned itself over the last few years. Spurred by the pandemic, the industry has seen a rise in digitalization efforts to maintain the relationships between the company, employees, and customers. To operate in the financial services industry in Singapore, a company must obtain the necessary licenses.

Types of Financial Service Licenses in Singapore

Setting up a company offering financial services, especially in FinTech, in Singapore could be a strategic move. Ranked 2nd in growth by industry in Singapore by the Ministry of Trade, the finance and insurance industry is expected to grow 4-5% per annum from 2021 to 2025, according to the Monetary Authority of Singapore (MAS).

To operate a financial service company, you must obtain one of the key financial service licenses in Singapore:

  • Capital Market Services (CMS) License

  • Financial Adviser’s (FA) License

Capital Market Services License in Singapore

Those who conduct activities which are regulated by the Securities and Futures Act must apply for a Capital Markets Services License, unless exempted. These activities include:

  • Dealing in securities
  • Trading in futures contracts
  • Securities financing
  • Providing custodial services for securities
  • Leveraged foreign exchange trading
  • Advising on corporate finance matters
  • Fund management
  • Real estate investment trust management

The CMS License in Singapore can only be applied by corporations. If an individual intends to act as a representative of the CMS License holder in conducting any of the above activities, the individual will need to acquire the related CMS Representative’s License, unless there is an exemption.

Financial Adviser’s License in Singapore

Those who conduct activities that are regulated by the Financial Advisers Act must apply for the Singapore Financial Adviser’s License. These activities include:

  • Providing advice on investment products such as securities and unit trusts, futures contracts, life insurance policies including investment-linked life insurance policies), foreign exchange and leveraged foreign exchange contracts, and other structured products
  • Issuing reports on investment products
  • Making arrangements for life insurance products
  • Marketing collective investment schemes such as unit trusts

The Financial Services Act in Singapore does not regulate the following areas:

  • Bank deposits – regulated under the Banking Act.
  • General insurance – arranged by intermediaries according to the Insurance Act and not considered to be an investment product.
  • Loans and mortgages – not regulated, also not investment activities.

Similar to the CMS license, only corporations can apply for the FA license and individuals acting as a representative of the FA license holder will need to acquire the FA Representative’s License, unless exempted.

Exempted Entities for CMS & FA Licenses in Singapore

There are some entities who do not apply for such licenses. The list includes the following:

Capital Market Service License Financial Adviser’s License
Banks, merchant banks, finance companies, and insurance companies – these entities are already regulated by the Monetary Authority of Singapore (MAS) under a separate legislation Banks, merchant banks, finance companies, and insurance companies – these entities are already regulated by the Monetary Authority of Singapore (MAS) under a separate legislation
Individuals who are acting on behalf of an exempt person Individuals who are acting on behalf of an exempt person
Individuals who are acting on behalf of CMS license holders who are engaged in custodial services for securities or securities financing Individuals who are Singaporean residents and act (directly or indirectly) as financial advisers who give advice on investment products excluding life insurance policies to no more than 30 accredited investors on any occasion. An accredited investor is an individual whose income over the preceding 12 months is either S$300,000 or whose net personal assets exceed S$2 million, a corporation with a net asset amount that exceeds S$10 million, or a trustee of a trust.
Individuals who are employees of banks or merchant banks and who are registered as associate persons of the Singapore Exchange Derivatives Trading Ltd.
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Eligibility Criteria for Financial Services Licenses Application in Singapore

As with every business license, there is a set of eligibility criteria that you must fulfil before applying for them. The requirements for CMS and FA licenses are listed below.

Corporate Structure and Activities
  • The application must be for a corporation.
  • The corporation’s primary business activity must align with the regulated activities specified in the Second Schedule to the Securities and Futures Act.
Track Record and Management
  • Evidence of a positive track record, management skills, and financial soundness over the preceding five years.
  • This requirement extends to any parent company of major shareholders.
Business Plans and Projections
  • The corporation must have clear business plans and future financial projections in place.
Internal Compliance Systems
  • Adequate internal compliance systems must be established and operational.
Financial Requirements
  • The corporation must satisfy the minimum financial requirements listed in the Securities and Futures Act.
Personal Status of Key Individuals
  • The personal status of the applicant, employees, officers, and substantial shareholders must meet MAS standards.
Key Personnel
  • Approval from the Monetary Authority of Singapore (MAS) to hire a CEO or Director who is a Singaporean resident.
  • At least two full-time employees must be involved in each of the regulated activities for which the corporation is seeking a license.
  • These employees must also hold a Representative’s License for the respective activities.
Capital Requirements for Specific Activities
  • For securities dealing: Cumulative shareholders’ funds of S$200 million.
  • For futures contract trading: Cumulative shareholders’ funds of S$100 million.
  • For fund management: At least S$1 billion in global funds under management.
Insurance Requirements
  • For fund management or advising on corporate finance matters, MAS may require a Professional Indemnity Insurance policy, compliant with MAS’s basic requirements.
Applicant Status
  • Application must be for an individual aged 21 years or older.
Qualifications and Examination
  • Applicant must meet the minimum academic qualification and examination requirements as stated by MAS.
Fit and Proper Criteria
  • Applicant must fulfill MAS’s criteria for being a fit and proper person.
Corporate Structure and Presence
  • Application must be for a corporation with a physical presence in Singapore.
Financial Requirements
  • Applicant must meet the minimum financial requirements as outlined in Regulation 15 of the Financial Advisers Regulation.
Business Plans and Projections
  • The corporation must have clear business plans and future financial projections in place.
Internal Compliance Systems
  • Adequate internal compliance systems must be established and operational.
Personal Status of Key Individuals
  • The personal status of employees, officers, and substantial shareholders must meet MAS standards.
Industry Experience
  • At least three years of experience in the financial advisory industry.
  • Executive directors, including the CEO, must have at least five years of relevant experience and the proper academic and professional qualifications.
Insurance Requirements
  • Active professional indemnity insurance policy with a minimum coverage of S$500,000.
  • The allowable deductible must not exceed 20% of the applicant’s net asset value at the end of the preceding financial year.
Applicant Status
  • An individual aged 21 years or older must submit the application.
Qualifications and Examination
  • Applicant must meet the minimum academic qualification and examination requirements as stated by MAS.
Fit and Proper Criteria
  • Applicant must fulfill MAS’s criteria for being a fit and proper person.

Procedure for Applying the Financial Service Licenses in Singapore

The procedure to apply for both CMS and FA licenses is as follows.

  1. Complete all application forms and submit them to MAS, along with supporting documents
  2. Payment of fee during the application process
  3. Successful applicants will receive their CMS license or CMS Representative’s License and Annual License Fee Advice – the license is valid for 3 years.

You must submit the license renewal at least 1 month before it expires.

How the MRA Grant Can Support Your Financial Services Business?

The Market Readiness Assistance (MRA) Grant can be leveraged to ease the costs associated with expanding your financial services company to Singapore. This grant is designed to help businesses enter new markets and could provide support in the following ways:

Regulatory and Licensing Compliance

MRA can subsidize costs for legal and consulting services needed to obtain CMS or FA licenses, ensuring your company adheres to MAS regulations.

Market Entry Strategy

Use MRA funding to conduct market research and strategy development, helping you better understand Singapore’s financial sector and identify niche opportunities within FinTech or advisory services.

Business Setup Assistance

MRA can cover a portion of costs related to company incorporation, office setup, and hiring professional service providers to ensure compliance with Singapore’s business environment.

Brand Development and Marketing

MRA can also support initiatives like branding, advertising, and promotional efforts to establish your company’s presence and attract clients in Singapore’s competitive financial market.

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