SGX Rules for Trading Representatives¶

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The Singapore Exchange (SGX) maintains specific rules governing trading representatives who operate on its markets. Trading representatives are individuals authorised to execute trades on SGX-ST (Securities Trading) and SGX-DT (Derivatives Trading) on behalf of SGX member firms. These rules complement MAS regulatory requirements and impose additional obligations on trading representatives and their employing member firms.

Registration Requirements¶

Who Must Register¶

Any individual who performs the following activities on behalf of an SGX member firm must be registered as a trading representative:

Executing orders in securities on SGX-ST
Executing orders in derivatives contracts on SGX-DT
Making markets in securities or derivatives listed on SGX
Operating algorithmic or automated trading systems that submit orders to SGX

Registration Prerequisites¶

Requirement	Details
CMFAS Modules	M1A (securities) and/or M2 (futures) as applicable to trading activity (M1A retired April 2024 — replaced by RES-1A under SFA 04-N22; M2 retired April 2024 — replaced by RES-2A/RES-2B)
Product Knowledge	M6 or M6A (securities/futures product knowledge) (M6/M6A retired April 2024 — replaced by CM-EIP or CM-SIP under SFA 04-N22)
Age	Minimum 21 years
Fit and Proper	MAS fit and proper criteria, no disqualifying criminal record or regulatory sanctions
Employment	Must be employed by an SGX member firm with a valid CMS licence
Sponsorship	Must be sponsored by the employing member firm

Registration Process¶

The employing member firm submits a registration application to SGX
SGX verifies CMFAS examination results with IBF
SGX conducts background checks (regulatory history, criminal record)
SGX may interview the applicant
Upon approval, the trading representative is assigned a unique SGX representative ID
The representative's details are published on the SGX member directory

Representative Categories¶

Category	Description	Trading Access
Securities Trading Representative	Authorised to trade listed securities on SGX-ST	SGX-ST order entry
Derivatives Trading Representative	Authorised to trade futures and options on SGX-DT	SGX-DT order entry
Dual Representative	Authorised for both securities and derivatives	SGX-ST and SGX-DT

Trading Representative Obligations¶

Pre-Trade Obligations¶

Client Verification — Verify client identity and account status before accepting orders
Suitability Check — Ensure client understanding of product risks for complex products
Order Accuracy — Confirm order details (security, quantity, price, order type) with client
Account Authority — Verify that the person placing the order is authorised for the account
Credit Check — Ensure the client's account has sufficient buying power or margin

Order Handling Requirements¶

Trading representatives must comply with SGX Rules on order handling:

Timestamp all orders — Record the time of order receipt, entry, and execution
Priority of client orders — Client orders must take priority over proprietary orders at the same price
Best execution — Take reasonable steps to achieve best execution for client orders
No front-running — Prohibited from trading ahead of client orders
Order routing — Follow firm's order routing policies and disclose routing practices
Error handling — Immediately report and rectify any order entry errors

Post-Trade Obligations¶

Trade Confirmation — Ensure trade confirmations are sent to clients within prescribed timeframes
Settlement — Monitor settlement obligations (T+2 for securities)
Record Keeping — Maintain records of all orders and trades for minimum 5 years
Client Reporting — Provide periodic account statements as required
Dispute Documentation — Document any client disputes or complaints related to trades

Continuing Education Requirements¶

SGX Continuing Education Programme¶

In addition to MAS CPD requirements, SGX imposes its own continuing education programme for trading representatives:

Requirement	Details
Annual Requirement	Completion of SGX-prescribed e-learning modules
Content	SGX rule changes, market structure updates, trading system updates
Format	Online modules via SGX Academy portal
Completion Deadline	By 31 December of each calendar year
Verification	Automated tracking via SGX Academy platform

SGX Rule Awareness Programme¶

When SGX introduces significant rule changes, trading representatives may be required to complete supplementary training:

New product launches — Mandatory briefing on new product specifications and risks
Trading system upgrades — Training on new trading platform features and procedures
Rule amendments — Awareness modules on amended trading rules and practice notes

Code of Conduct for Trading Representatives¶

General Conduct Standards¶

SGX trading representatives are expected to:

Act with integrity — Conduct all business honestly and fairly
Exercise due care — Apply reasonable skill and diligence in all trading activities
Maintain confidentiality — Protect client information and order flow
Avoid conflicts — Declare and manage conflicts of interest
Cooperate with regulators — Respond promptly to SGX and MAS enquiries

Prohibited Activities¶

Prohibited Activity	Description	Reference
Market manipulation	Artificial price inflation/deflation through wash trades, matched orders	SGX Rules Chapter 13
Insider trading	Trading on material non-public information	SFA s218–s219
Front-running	Trading ahead of client orders for personal benefit	SGX Rules Chapter 12
Churning	Excessive trading in client accounts to generate commissions	SGX Rules Chapter 12
Misrepresentation	Providing false or misleading information to clients	SGX Rules Chapter 12
Unauthorised trading	Executing trades without proper client authorisation	SGX Rules Chapter 12
Sharing of trading IDs	Allowing another person to use one's trading credentials	SGX Rules Chapter 4

Personal Account Trading¶

Trading representatives must comply with personal account dealing policies:

Pre-clearance of personal trades with compliance department
Holding period restrictions (typically minimum 1 month)
Reporting of personal trading activity
Restrictions on trading in securities covered by the representative's research or order flow
Prohibition on trading during blackout periods (e.g., before earnings announcements of covered companies)

Disciplinary Framework¶

SGX Enforcement Powers¶

SGX has the authority to take disciplinary action against trading representatives who breach its rules:

Action	Application	Duration
Private warning	Minor first-time breaches	Recorded for 3 years
Public reprimand	Moderate breaches, published on SGX website	Permanent record
Fine	Up to SGD 250,000 per breach	As specified in decision
Suspension	Serious breaches, temporary bar from trading	Up to 3 years
Revocation	Severe or repeated breaches, permanent bar	Permanent

Disciplinary Process¶

Detection — Breach identified through market surveillance, inspection, or complaint
Investigation — SGX Regulatory Division investigates the matter
Show cause — Representative and firm are given opportunity to respond
Hearing — Disciplinary committee convenes to hear the case (for serious matters)
Decision — Committee issues decision with reasons
Appeal — Right to appeal to SGX Appeals Committee within 14 days
Publication — Disciplinary actions (except private warnings) are published

Reporting to MAS¶

SGX is required to report significant disciplinary actions to MAS. MAS may take additional regulatory action, including:

Issuing prohibition orders under SFA s101
Revoking the representative's appointment
Taking enforcement action against the employing firm

Cessation and Transfer¶

Cessation of Registration¶

A trading representative's SGX registration ceases when:

The representative leaves the employing member firm
The representative's MAS appointment is revoked or not renewed
The representative fails to meet continuing education requirements
The representative is subject to a revocation order by SGX

Transfer Between Firms¶

When a trading representative transfers to another SGX member firm:

The departing firm notifies SGX of the representative's cessation
The new firm submits a fresh registration application
SGX reviews the representative's disciplinary history
A new representative ID may be issued
The representative cannot trade until the new registration is approved

Relevance to Regnify¶

Regnify's compliance platform interacts with SGX trading representative rules in several ways:

Registration Status Tracking — Monitoring SGX registration status alongside MAS appointment status
Continuing Education Monitoring — Tracking SGX continuing education completion alongside MAS CPD
Disciplinary History — Recording any SGX disciplinary actions as part of the fit and proper assessment
Transfer Management — Managing the registration transition when representatives move between firms

Source Documents¶

SGX-ST Rules, Singapore Exchange Limited
SGX-DT Rules, Singapore Exchange Limited
SGX Practice Notes and Directives
SGX Disciplinary Proceedings Annual Report
Last verified: 2026-03-15