MAS Form 3C (SFA) -- Temporary Representative Appointment¶
Source: SFA/SF(LCB)R Form 3C (Revised 8 October 2018) Legislation: Securities and Futures Act (Cap. 289) s99F Regulations: SF(LCB)R Reg 3A
Overview¶
Form 3C is the notification for appointing a temporary representative under the SFA only (not the FAA). It is used for overseas employees of a principal who need to conduct regulated activities in Singapore on a temporary basis, typically individuals with at least 5 years of relevant experience.
Key distinction from Form 3B: Form 3C is SFA-only, covers a defined appointment period (From/To dates), and requires the principal to provide reasons for the temporary appointment. The individual must have status with overseas regulatory bodies comparable to Singapore's requirements.
Key Rules¶
- Must be submitted by an authorised person of the principal.
- Once the individual's name is entered into MAS's Register of Representatives, the principal cannot withdraw the form.
- A principal shall not permit any individual to provide any type of regulated activity under the SFA unless that individual is appointed as a temporary representative for that specific activity type.
- A non-refundable lodgment fee is payable (prescribed under SF(LCB)R Reg 6).
- The form should be completed only after ensuring the criteria in SFA s99F and relevant Regulations and Notices have been satisfied.
- Maximum appointment: 6 months per appointment, up to 24 months total.
Form Sections¶
1. General Information¶
| Field | Required | Notes |
|---|---|---|
| Full name of company (Principal) | Yes* | Legal entity name |
| Prior regulated activity since 26/11/2010 | Yes* | If Yes, provide existing Representative Number |
| Representative number | Conditional | Only if previously registered |
| Name as reflected in NRIC/FIN/Passport | Yes* | Must match identity document |
2. Personal Information¶
| Field | Required | Notes |
|---|---|---|
| Main email address | Yes* | |
| Alternate email address | No | |
| Mobile telephone no. | Yes* | |
| Date of birth (DD/MM/YYYY) | Yes* | |
| Gender | Yes* | Male / Female |
| Nationality type | Yes* | SG Citizen / SG PR (specify) / Others (specify) |
| NRIC number | Conditional | Compulsory for SG Citizen or SG PR |
| FIN | Conditional | Compulsory for non-Singaporean (once available) |
| Passport number | Conditional | Compulsory for non-Singaporean |
3. Proposed Activity/Activities (SFA Only)¶
Under the SFA: - Dealing in capital markets products: - Securities - Units in a collective investment scheme - Exchange-traded derivatives contracts - Over-the-counter derivatives contracts - Spot FX contracts (leveraged FX trading) - Fund management - Real estate investment trust management - Providing credit rating services - Advising on corporate finance
Proposed commencement period: From* (date) -- To (date). The effective date may differ from the proposed date. The individual must be listed on the Register of Representatives as "Temporary" before commencing any regulated activity.
4. Status with Other Regulatory Bodies or Exchanges¶
Only individuals from jurisdictions whose laws and practices are assessed by MAS as comparable to Singapore may be successfully notified as temporary representatives.
Disclose status in the past 2 years with: - (a) Any overseas regulatory authority (financial services) - (b) Any overseas securities exchange(s)
Table columns: Name of Authority/Exchange | Status (Licensed/Registered/Approved/Others) | Description of regulated activities | Principal corporation | Period (From -- To)
Reason for temporary appointment (mandatory free-text field).
5. Fit and Proper Certification¶
The principal certifies, based on due diligence (including reference checks with past employers), that it: - Is satisfied the individual is not subject to bankruptcy petition or undischarged bankrupt - Is satisfied there is no conflict of interest from the individual's shareholdings/directorships - Is satisfied the individual meets all requirements under Entry Requirements of a Provisional or Temporary Representative [Notice SFA 04-N10] - (Choose one): - Is not aware of any adverse information, OR - Is aware of adverse information but has assessed and considers the individual meets Fit and Proper Criteria under Guideline FSG-G01, with undertaking to closely supervise - Is aware that due diligence records must be documented and properly kept per SFA s99H(4) - Is satisfied the individual meets all other requirements under FSG-G01 (except examination requirements) - Is satisfied the individual is not in arrears on CPF contributions (Self Employed Persons Regulations, Rg 25), where applicable
CPF declaration is mandatory for all individuals applying to become appointed, provisional, or temporary representatives, regardless of CPF obligation status.
6. Undertaking¶
The principal undertakes, for all regulated activities carried out by the temporary representative: - To put in place measures (including proper training) to ensure the individual understands and complies with all Singapore laws relevant to their activities - To ensure the individual is accompanied at all times by persons referred to in SF(LCB)R Reg 3A(6) when meeting any client or public - To ensure the individual sends concurrently to supervisory persons all electronic mail sent to clients - To ensure the individual does not communicate by telephone with clients except by telephone conference in the presence of supervisory persons
7. Declaration¶
Submitted by a Director / Chief Executive / CEO of the Principal, certifying: - (a) The individual is believed fit and proper for the function of a representative - (b) The information is true and correct to the best of the Principal's knowledge
Regnify Implementation Notes¶
- Form 3C maps to representative type
TEMPORARYwith strict period tracking (From/To dates). - The Undertaking section imposes supervision requirements that differ from Forms 3A/3B -- the system should flag these obligations in the approval workflow.
- The reason for temporary appointment is a required justification field not present in other forms.
- The 6-month / 24-month maximum rules should be enforced as validation logic.
- No FAA activities are available on this form (SFA-only).