SGX-ST Member Rules Relevant to Representatives¶

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Overview¶

SGX-ST (Singapore Exchange Securities Trading) member rules establish the operational framework within which member firms and their representatives must operate. These rules govern order handling, client communication, error trade management, and other operational matters that directly affect the daily activities of trading representatives. This document focuses on the rules most relevant to representative conduct and compliance.

Order Handling Rules¶

Order Types and Specifications¶

SGX-ST supports the following order types that representatives must understand:

Order Type	Description	Key Rules
Limit Order	Buy/sell at a specified price or better	Must specify price within allowable tick size
Market Order	Execute immediately at best available price	Subject to price banding limits
Stop Order	Triggered when price reaches a specified level	Converted to market/limit order upon trigger
Market-to-Limit	Execute at market price, remainder becomes limit	Prevents excessive price impact
Fill-or-Kill (FOK)	Execute entire order immediately or cancel	No partial fills allowed
Fill-and-Kill (FAK)	Execute immediately what can be filled, cancel remainder	Partial fills allowed

Order Entry Requirements¶

Representatives must comply with the following when entering orders:

Correct Account Designation — All orders must be entered under the correct client account number
Segregation of Proprietary and Client Orders — Proprietary orders must be clearly distinguished from client orders
Price Banding — Orders outside the allowable price band are rejected by the system
Lot Size — Board lots (typically 100 shares) for regular trades; odd lot market for smaller quantities
Amendment and Cancellation — Order amendments must be timestamped and logged; cancellations must be documented with reason

Best Execution Obligation¶

SGX member firms and their representatives have a best execution obligation:

Price — Achieve the best available price for the client
Speed — Execute orders promptly without unnecessary delay
Likelihood of execution — Consider market depth and liquidity
Cost — Minimise transaction costs where possible
Documentation — Maintain records demonstrating best execution was achieved

Order Priority Rules¶

Rule	Description
Price-Time Priority	Orders at the same price are executed in the order received
Client Order Priority	Client orders must be executed before or at the same time as proprietary orders at the same price
No Frontrunning	Representatives must not trade ahead of pending client orders
Aggregation Rules	If aggregating client orders, allocation must be fair and pre-determined

Client Communication Rules¶

Pre-Trade Disclosure¶

Before executing trades, representatives must ensure clients are informed of:

Commission and Fees — All applicable commissions, clearing fees, SGX trading fees, and GST
Product Risks — Specific risks associated with the securities being traded
Margin Requirements — If trading on margin, full disclosure of margin terms and risks
Contract Specifications — For derivatives, full disclosure of contract specifications
Settlement Obligations — T+2 settlement cycle and consequences of settlement failure

Fee Disclosure¶

Fee Component	Description	Typical Rate
Brokerage Commission	Member firm's trading commission	0.08%–0.28% (negotiable)
SGX Trading Fee	Exchange trading access fee	0.0075%
SGX Clearing Fee	CDP clearing fee	0.0325%
GST	Goods and Services Tax on fees	9% of commission and fees
SGX Settlement Fee	Settlement instruction fee	SGD 0.35 per settlement instruction

Trade Confirmation Requirements¶

Representatives must ensure trade confirmations are issued containing:

Date and time of execution
Security description and ISIN
Quantity executed
Execution price
Trade amount
Commission and fees charged
Settlement date and amount
Whether the firm acted as agent or principal

Periodic Client Statements¶

Member firms must provide:

Monthly statements — For accounts with trading activity
Quarterly statements — For all active accounts (even without trading activity)
Annual tax statement — Summary of realised gains/losses and dividends received

Communication Standards¶

All client communications by representatives must:

Be accurate, clear, and not misleading
Present a balanced view of risks and potential returns
Not contain guarantees of future performance
Comply with MAS Guidelines on Standards of Conduct for Marketing and Distribution
Be retained by the firm for at least 5 years

Error Trade Management¶

Definition of Error Trades¶

An error trade occurs when:

A trade is executed at the wrong price, quantity, or in the wrong security
A trade is executed for the wrong client account
A trade is executed without proper client authorisation
A system malfunction causes unintended trade execution

Error Trade Procedures¶

Immediate Actions¶

Detection and Notification — Representative must immediately notify their supervisor and compliance when an error trade is identified
Documentation — Complete an error trade report within 1 business day, documenting the error, its cause, and the corrective action taken
Client Notification — If the error affects a client, the client must be notified promptly

Resolution Options¶

Resolution Method	Description	Applicability
Offsetting Trade	Enter an opposite trade to close the erroneous position	When market conditions allow without excessive loss
Trade Cancellation	Request SGX to cancel the trade (mutual agreement or clearly erroneous)	Within SGX's trade cancellation policy timeframes
Account Transfer	Transfer the trade from client account to error account	When the trade should not have been in the client's account
Absorption by Firm	Firm absorbs the loss from the error trade	When no other resolution is practical

SGX Clearly Erroneous Trade Policy¶

SGX may cancel or adjust trades that are "clearly erroneous" based on the following criteria:

The trade price deviates from the reference price by more than the prescribed threshold
The request is submitted within the prescribed timeframe (typically within 30 minutes)
Both counterparties are notified and given opportunity to object
SGX's decision on clearly erroneous trades is final

Error Trade Reporting¶

Reporting Obligation	Timeframe	Recipient
Internal error report	Within 1 business day	Compliance department
Client notification	Promptly upon detection	Affected client
SGX trade cancellation request	Within 30 minutes of detection	SGX Market Surveillance
MAS reporting (if material)	As required under regulatory reporting	MAS supervision team

Error Trade Record-Keeping¶

Member firms must maintain records of all error trades including:

Details of the erroneous trade (date, time, security, quantity, price)
Description of the error and root cause
Name of the responsible representative
Corrective action taken
Financial impact (profit or loss)
Supervisory review and sign-off
Retention period: minimum 5 years

Margin Trading Rules¶

Margin Account Requirements¶

For representatives handling margin trading accounts:

Margin Agreement — Client must sign a margin agreement before any margin trading
Risk Disclosure — Separate risk disclosure statement for margin trading
Initial Margin — Minimum margin deposit before opening positions
Maintenance Margin — Ongoing margin requirement (typically 140% of debit balance)
Margin Call — Client must be notified when margin falls below maintenance level
Force Sell — Firm may liquidate positions if margin call is not met within prescribed period

Concentration Limits¶

Limit Type	Threshold	Action Required
Single security concentration	>10% of account value	Enhanced monitoring
Single security concentration	>25% of account value	Additional margin or reduce position
Contra trading exposure	Subject to firm-specific limits	Monitor and enforce within limits

Short Selling Rules¶

Regulated Short Selling (RSS)¶

SGX permits regulated short selling subject to the following rules:

Only designated securities are eligible for short selling
Short sell orders must be marked as "short" in the trading system
Uptick rule: short sell orders must be entered at a price not lower than the last traded price
Securities must be borrowed before settlement (no naked short selling)
Daily short selling limits apply per security

Securities Borrowing and Lending (SBL)¶

Representatives involved in SBL must comply with:

SBL agreements must be documented with standardised terms
Collateral requirements for borrowed securities
Reporting of SBL transactions to SGX
Return obligations upon recall by the lender

Market Integrity Rules¶

Trading Halts and Suspensions¶

Representatives must be aware of and comply with:

Trading Halt — Temporary halt (usually 30 minutes to 1 hour) for material announcements
Suspension — Longer-term trading suspension by SGX or at company request
Circuit Breakers — Market-wide circuit breakers triggered by extreme price movements (5% for STI component stocks, 10% for others)
Dynamic Price Banding — Automatic rejection of orders outside dynamic price bands

Reporting of Suspicious Activities¶

Representatives must report to their compliance department:

Unusual trading patterns that may indicate market manipulation
Potential insider trading activities
Client attempts to place orders that may breach regulations
Any information suggesting market abuse

Relevance to Regnify¶

These SGX member rules are relevant to Regnify's compliance platform in several ways:

Competency Verification — Ensuring representatives understand order handling and best execution obligations
Error Trade Tracking — Monitoring error trade frequency and patterns as part of representative performance assessment
Compliance Monitoring — Tracking adherence to client communication and disclosure requirements
Fit and Proper Assessment — Disciplinary actions related to rule breaches factor into the fit and proper evaluation
Training Needs Identification — Identifying areas where representatives may need additional training based on rule compliance patterns

Source Documents¶

SGX-ST Rules, Singapore Exchange Securities Trading Limited
SGX-ST Practice Notes and Directives
SGX CDP Clearing Rules
SGX Market Surveillance Guidelines
Last verified: 2026-03-15

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