Supporting Document Upload Requirements¶
Overview¶
All MAS representative appointment forms (3A, 3B, 3C) require supporting documents to be submitted alongside the form data. In Regnify, documents are uploaded to S3 storage and linked to the declaration. At least one supporting document must be attached before a declaration can be submitted for review. This guide covers the specific requirements for each document category, file specifications, and common issues.
General Upload Specifications¶
| Specification | Value |
|---|---|
| Accepted file format | PDF only (application/pdf) |
| Maximum file size | 5 MB per document |
| Minimum documents | 1 document required before submission |
| Upload timing | Documents can only be uploaded after the declaration is saved (requires declaration_id) |
| Upload statuses | New files can be uploaded in Draft, Rejected, and MAS_REJECTED statuses |
| Delete permissions | Documents can only be deleted when the declaration is in Draft status |
| Category editing | Representatives can change category in Draft/Rejected/MAS_REJECTED; approvers can change category during Pending Review |
Document Categories¶
1. Identification Document (IC / Passport / EP)¶
Category value: identification
Purpose: Verify the identity of the individual being appointed.
Requirements: - Singapore Citizens/PRs: Clear copy of NRIC (front and back) - Must show full name, NRIC number, photograph, date of birth - Must be current and unexpired - Non-Citizens: Clear copy of passport (bio-data page) - Must show full name, passport number, photograph, nationality, date of birth - Passport must be valid (not expired) - If an Employment Pass (EP) or S Pass has been issued, include a copy of the pass - Quality requirements: Legible, all text clearly readable, no glare or shadows obscuring information - Common errors: Expired documents; only front of NRIC provided (back is also needed); low-resolution scans; name on document does not match form entry
2. Education Certificate¶
Category value: education
Purpose: Verify the individual's highest educational qualification.
Requirements: - Certificate or diploma from the awarding institution - Must show: full name of graduate, qualification title, institution name, date of conferral - If the certificate is in a language other than English, a certified translation must be provided - For overseas qualifications, include verification from the issuing institution or a credential evaluation service - Common errors: Providing transcripts instead of the actual certificate; name on certificate differs from current legal name (e.g., maiden name)
3. CMFAS Exam Modules¶
Category value: cmfas
Purpose: Prove the individual has passed the required Capital Markets and Financial Advisory Services examinations.
Requirements for Form 3A (Appointed Representative): - CMFAS examination result letters or certificates for ALL modules required for the proposed activities - Must show: candidate name, module code and name, examination date, result (Pass), certificate number - Results must be current — some modules have validity periods - The modules must correspond to the activities selected in the Proposed Activity/Activities section
Requirements for Form 3B (Provisional Representative): - Examination registration confirmation or schedule for planned modules - Any modules already passed should include certificates
Requirements for Form 3C (Temporary Representative): - If seeking CMFAS waiver: equivalent overseas qualification certificates - If not seeking waiver: same as Form 3A
CMFAS Module Mapping to Activities (effective 1 April 2024; SFA04-N22 / FAA-N26):
Note: The CMFAS module regime changed on 1 April 2024. Old M-series certificates (M1A, M2, M3, M4, M5, M6, M6A, M8, M8A, M9, M9A, M10) are grandfathered and remain acceptable for representatives appointed before that date. New appointees from 1 April 2024 onward must present certificates for the new RES/CM modules. Both old and new certificates should be accepted during the transition period.
| Activity | New Module(s) from 1 Apr 2024 | Old Module(s) — grandfathered |
|---|---|---|
| Dealing in Securities (exchange-traded) | RES-1A + CM-EIP | M1A, M6 or M6A |
| Trading in Futures Contracts | RES-2A + CM-EIP | M2, M6 or M6A |
| Leveraged FX Trading | RES-2B + CM-EIP | M3, M6 or M6A |
| Advising on Corporate Finance | RES-4 + CM-EIP | M4, M6 or M6A |
| Financial Advisory Services (securities) | RES-5 + CM-SIP | M5, M6 or M6A |
| Financial Advisory Services (CIS) | RES-5 + CM-CIS | M5, M8 or M8A |
| Financial Advisory Services (life insurance) | RES-5 + CM-LIP | M5, M9 or M9A |
| Fund Management | RES-3 + CM-EIP | M5, M6 or M6A |
Common errors: Missing certificates for required modules; expired module results; module does not match the proposed activity; certificate name does not match NRIC name; presenting old M-series certificates without checking grandfathering eligibility
4. Credit Bureau Report (CBS)¶
Category value: credit_bureau
Purpose: Assess the individual's financial standing as part of due diligence requirements.
Requirements: - Report obtained from the Credit Bureau Singapore (CBS) - Must be dated within 3 months of the submission date - Types accepted: CBS Credit Report, CBS Litigation Search, or combined report - Must show: individual's name, NRIC/FIN, credit score summary, payment history, outstanding obligations, default records, bankruptcy searches, litigation records - The report should be in the individual's name (not the principal's)
How to obtain: - Online via www.creditbureau.com.sg - At selected SingPost branches - Through the principal's CBS corporate account
Common errors: Report older than 3 months; report in someone else's name; only the credit score summary without full details; CBS Litigation Search missing (needed alongside the credit report)
5. Resume¶
Category value: resume
Purpose: Document the individual's employment history, skills, and experience.
Requirements: - Comprehensive CV/resume covering at least the past 10 years of employment - Must include: chronological employment history with employer names, job titles, dates, key responsibilities - Gaps in employment exceeding 3 months must be explained - Previous appointments as a representative (if any) must be listed with MAS representative numbers - Education and professional qualifications should be included - Professional certifications and training courses should be listed
Common errors: Gaps in employment not explained; previous representative appointments not listed; resume not up to date; resume does not cover full 10-year history
6. CPF Statement¶
Category value: cpf
Purpose: Verify employment status and CPF contribution history.
Requirements: - CPF Contribution History Statement for the past 12-24 months - Available from the CPF website (my.cpf.gov.sg) under "My Statement" - Shows: employer names, contribution amounts, contribution period - Useful for verifying employment history claims
Common errors: Statement too old; does not cover the relevant employment period
7. Employment History¶
Category value: employment_history
Purpose: Verify past employment claims, particularly for reference checks.
Requirements: - Reference letters or employment verification letters from previous employers (past 5 years) - Should include: employer name, position held, employment dates, nature of duties - At least 2 reference letters recommended for due diligence compliance - Letters should be on company letterhead with contact details of the signatory
Common errors: Reference letters too vague (no dates, no position details); letters not on official letterhead; reference contact cannot be reached for verification
8. License¶
Category value: license
Purpose: Document any existing professional licenses or registrations.
Requirements: - Copies of current professional licenses (e.g., CFA charter, CFP certification, overseas regulatory licenses) - Must show: holder's name, license type, issuing authority, validity period - For overseas regulatory licenses, include a letter of good standing from the regulator
Common errors: Expired licenses; license does not relate to the proposed activities
9. Professional Qualifications¶
Category value: professional_qualifications
Purpose: Document professional certifications beyond educational qualifications.
Requirements: - Certificates for professional designations (CFA, CFP, CAIA, FRM, etc.) - Training completion certificates for relevant courses - Continuing Professional Development (CPD) records if applicable
10. Fit and Proper Check¶
Category value: fit_and_proper_check
Purpose: Document the principal's Fit and Proper assessment.
Requirements: - Completed Fit and Proper assessment form (internal) - Criminal record check results (or declaration of no criminal record) - Regulatory action search results - Bankruptcy search results - Any adverse findings and the assessment rationale
In Regnify: The Fit and Proper module generates a PDF on submission, stored at fit-and-proper/<check_id>/declaration.pdf. This can be attached as a supporting document.
11. CPF Contribution Record (Self-Employed)¶
Category value: cpf_contribution
Visibility: Only shown when the individual's relationship with the principal is "Self employed"
Purpose: Verify CPF contributions for self-employed individuals as required by the CPF (Self Employed Persons) Regulations.
Requirements: - CPF self-employed contribution record - Shows that the individual is not in arrears in CPF contributions - Aligns with the Required Declaration checkbox for CPF non-arrears
Document Upload Workflow in Regnify¶
Step-by-Step Upload Process¶
- Save declaration first — Documents require a
declaration_id, so the form must be saved at least once (even as Draft) - Navigate to the Supporting Documents section
- Click Upload — Select a PDF file (max 5 MB)
- Set document category — Choose from the dropdown (e.g., "Resume", "CMFAS Exam Modules")
- Confirm upload — File is uploaded to S3 and linked to the declaration
- Repeat for additional documents
Upload API¶
- Single upload:
POST /api/documents/uploadwith FormData fieldfile - Multi-upload:
POST /api/documents/upload-multiplewith FormData fieldfiles[] - Category update: Category can be changed after upload (in editable statuses)
- Delete:
DELETE /api/documents/{id}(only in Draft status)
S3 Storage Path¶
Documents are stored in S3 following this pattern:
<bucket>/declarations/<declaration_id>/<original_filename>
Recommended Document Checklist by Form Type¶
Form 3A (Appointed Representative)¶
| Document | Required/Recommended |
|---|---|
| NRIC or Passport copy | Required |
| CMFAS certificates (all required modules) | Required |
| Credit Bureau Report (within 3 months) | Required |
| Resume (10-year history) | Required |
| Employment verification letters (past 5 years) | Highly recommended |
| Education certificates | Recommended |
| Professional qualifications | If applicable |
| Fit and Proper check documentation | Required (internal) |
| CPF Statement | Recommended |
| CPF Contribution Record (self-employed only) | Required if self-employed |
Form 3B (Provisional Representative) — Additional¶
| Document | Required/Recommended |
|---|---|
| All Form 3A documents | Required |
| Overseas employment verification letters | Required |
| Overseas regulatory license copies | Required |
| CMFAS exam registration confirmations | Required |
| Supervision plan document | Required |
Form 3C (Temporary Representative) — Additional¶
| Document | Required/Recommended |
|---|---|
| All Form 3A documents | Required |
| Overseas employment verification letter | Required |
| Assignment/secondment agreement | Required |
| Overseas regulatory license copies | Required |
| Equivalent qualification certificates (if waiver sought) | Required if seeking CMFAS waiver |
| Reference from overseas compliance officer | Recommended |
Common Upload Issues¶
| Issue | Cause | Resolution |
|---|---|---|
| "Upload not available" | Declaration has not been saved yet | Save the declaration first (at least as Draft) |
| "File too large" | PDF exceeds 5 MB | Compress the PDF or split into multiple files |
| "Invalid file type" | File is not a PDF | Convert to PDF before uploading |
| Cannot delete document | Declaration is not in Draft status | Documents can only be deleted in Draft status |
| Category shows wrong type | Category was not set during upload | Edit the document category (available in editable statuses) |
| Upload fails | Network issues or S3 connectivity | Retry the upload; check network connection |
Source References¶
- MAS Practice Note on Representative Appointment — Required Documentation
- MAS Guidelines on Fit and Proper Criteria (FSG-G01) — Due Diligence Requirements
- Credit Bureau Singapore (CBS) — Report Types and Access
- Central Provident Fund Act — Self-Employed Persons Regulations