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MAS is looking to support Singapore Financial Institutions in focusing their efforts on meeting the challenges of Covid-19. Earlier this month, the regulator issued a series of Circulars announcing details of relief provided to CMSL holders (and others) with respect to reporting, licencing and examination requirements. The regulatory deadlines may have been delayed but they have not been relaxed, so understanding the timelines and expectations is as important as ever.
Periodic reportingÂ
The MAS has pushed back the submission deadlines for a large number of regulatory returns due between 8th April and 31st December 2020.
| Return(s) | Applies to | Old deadline | New deadline |
| Forms 1 and 2 (quarterly) | CMSL holders | 14 calendar days of quarter end | 28 calendar days of quarter end |
| Forms 1 to 6 (annual) | 5 months of FYE | 7 months of FYE | |
| Form 34 | Exempt Futures / OTC Derivatives Brokers | 5 months of FYE | 7 months of FYE |
| P&L account, Balance Sheet and Auditor’s Certification |
This week the MAS confirmed our understanding of the submission deadlines for the Quarterly Income and Expenditure returns as follows:
| Period | New deadline |
| Q1 2020 | 21st April |
| Q2 | 17th July |
| Q3 | 21st October |
| Q4 | TBC |
The following types of FI also benefit:
- CMSL holders providing credit rating services and / or product financing
- Approved Exchanges
- Approved Clearing Houses
- Recognised Clearing Houses
- Approved Holding Companies
- Licenced Trade Repositories
- Recognised Market Operators
Please see Circular CMI 17/2020 for further details.
Transaction reporting – OTC derivatives
The implementation of the final phase of reporting of OTCD has been pushed back by a year. Thus, CMSL holders and others will have until 1st October 2021 to commence reporting OTC commodity, equity and foreign exchange transactions.
Licencing and exempt status for certain derivatives brokers
The transitional period for OTC derivatives brokers to obtain the CMSL has been pushed back by twelve months to 8th October 2021. As has the deadline for brokers dealing in OTC derivatives or block futures contacts (that meet certain criteria) to register their exempt status with the MAS.
Exam requirements
Individuals appointed as representatives between 9th April and 30th September 2020 have been granted a 6-months grace period to pass the relevant CMFAS module. Representatives can therefore, subject to the conditions below, carry out regulated activities prior to passing regulatory exams. The Principal FI will be responsible for the following:
- Training the representative on the rules and regulations and product knowledge relevant to his / her role.
- Ensuring that the representative is appropriately supervised, including the need for them to be supervised by a specified person (i.e. an appointed representative of the FI, an approved director, etc.) when meeting with clients or prospective clients.
- Subjecting the sales or transactions carried out by the representative to greater scrutiny.
How we can help
While submission deadlines have been pushed back to provide relief to CMSL holders during this period, none of the reporting or licencing requirements have been removed per se. Indeed, the grace period relating to the exam requirements brings with it additional requirements on the part of the Principal FI. We are able to help you to meet these requirements, as well as to provide wider support. Please do get in touch.
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