The FAQ was updated on 8 October 2024 to provide guidance on computing the value of an Accreditor Investor’s (AI) holdings of digital payment tokens (DPTs).
Individual AI
From 4 October 2024, for the purposes of determining the value of an individual’s net personal assets, Financial Institutions (FIs) should adopt the following methodology to determine the value of the individual’s holdings of DPTs by –
- applying a haircut of at least 50% to the market value of the individual’s holdings of DPTs; and
- taking the value of the individual’s holdings of DPTs to be the lower of the following:
- the value calculated under (a); and
- S$200,000
FIs should disclose the methodology used to determine the value of DPT holdings and apply it fairly to all its customers.
The above treatment of DPTs will not apply to MAS-regulated stablecoins when assessing a customer’s AI eligibility.
Corporate AI
For the purposes of determining the value of net assets of a corporation or entity for determining eligibility as an AI, FIs should refer to the latest audited financial statements of the corporation/ entity, which should be prepared based on generally accepted financial reporting standards. If no audited financial statement is available, then the FI should adopt the same approach for valuing the customer’s holdings of DPTs as described above.
AI assessment performed before 4 October 2024 using DPT holdings
If an existing AI client’s DPT holdings were previously considered before 4 October 2024 in the calculation of net personal assets, FIs should re-assess whether such AI clients still meet the AI thresholds using the DPT valuation methodology.
If the FI determines that a client is unable to meet the revised AI threshold, the FI should not enter into any new transactions with the client, on the basis that the client is an AI. FIs should ensure that their records accurately reflect the client’s revised status after the re-assessment.
FIs should seek to complete all such re-assessments by 4 July 2025.
For the full details, please refer to the MAS website https://www.mas.gov.sg/regulation/faqs/faqs-on-the-definition-of-accredited-investor-and-opt-in-process
Disclaimer: The information, views or opinions expressed are provided for general information and should not be relied upon as legal or professional advice.