The information paper sets out MAS’ supervisory expectations, good practices observed and areas for enhancement when assessing whether appointed representatives are fit and proper to carry out regulated activities.
Some of the key supervisory expectations and good practices include having structured recruitment policies and processes approved by senior management, implementing risk mitigating measures (eg. enhanced monitoring), considerations when assessing adverse information, expected standards of conduct for representatives who are subjected to monitoring, evaluating the scope and appropriateness of training, and effective oversight on outsourced service providers who are conducting due diligence.
The paper also highlighted poor practices and weaknesses such as inadequate monitoring and supervision of representatives with adverse information, poorly designed oversight arrangements and ineffective control implementation, inadequate assessments of representatives’ conflicts-of-interest and financial soundness, deficient oversight and governance over third-party product training, poor oversight of assistants hired by representatives, and insufficient supervision over outsourced activities.
Financial institutions should benchmark their current policies, processes and procedures against the supervisory expectations and good practices in this paper, and take action to address any identified gaps.
For the full details, refer to https://www.mas.gov.sg/publications/monographs-or-information-paper/2025/thematic-review-of-financial-institutions-recruitment-and-onboarding-training-of-representatives
Disclaimer: The information, views or opinions expressed are provided for general information and should not be relied upon as legal or professional advice.