Singapore: MAS consults on proposals to mandate reference checks

To limit “rolling bad apples” across the broader segment of the financial industry, MAS is consulting on its proposal to introduce mandatory reference checks to a broader segment of the financial industry, beyond representatives and insurance broking staff to include senior management.

In brief

Currently, capital markets services licence holders, exempt financial institutions, licensed financial advisers and exempt financial advisers are expected to conduct reference checks on representatives that they intend to appoint under the Securities and Futures Act (SFA) and Financial Advisers Act (FAA). The Monetary Authority of Singapore (MAS) has recently confirmed that it will introduce a new framework, mandating these financial institutions, as well as insurance brokers, registered fund management companies and venture capital fund managers, to perform reference checks with current and previous employers of proposed representatives or broking staff (as the case may be), based on a set of minimum mandatory information. Financial institutions will also be mandated to respond to reference check request within a specified timeline. Please refer to our client alert Singapore: MAS finalises changes to misconduct reporting regime for representatives for further details.


On 14 May 2021, MAS issued the Consultation Paper on Proposals to Mandate Reference Checks.1 MAS proposes to introduce similar mandatory reference check requirements to a broader segment of the financial industry, requiring financial institutions (FIs) to perform and respond to reference checks on senior managers and other employees, based on a set of minimum mandatory information and within a specified period of time. This consultation closes on 25 June 2021.

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1 Please see:


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