title: Workflow: Annual Compliance Cycle for Appointed Representatives¶

Workflow: Annual Compliance Cycle for Appointed Representatives¶

Overview¶

Once a representative is appointed and registered with MAS, the principal has ongoing annual compliance obligations. This document covers the annual declaration cycle, Continuing Professional Development (CPD) requirements, CMFAS renewal, Fit and Proper re-assessment triggers, fee payments, and reporting deadlines.

Annual Compliance Calendar¶

Month	Obligation	Responsible Party
January	Annual representative fees due (for the current calendar year)	Principal (Finance)
January-March	Annual Fit and Proper re-declaration for all active representatives	Compliance Officer
Ongoing	CPD hours tracking (minimum hours per calendar year)	Representative + HR
Ongoing	Material change notifications (within 14 days of change)	Compliance Officer
December	Year-end compliance review — verify all obligations are met	Compliance Officer

Annual Representative Fees¶

Fee Structure¶

Fee Type	Amount	When Due
Annual fee (standard CMS activities)	$700 per representative	1 January each year
Annual fee (limited CMS activities)	$200 per representative	1 January each year
First-year fee (new appointments)	Pro-rated from appointment date to 31 December	Upon appointment

Key Rules¶

The annual fee is charged on a "highest of" basis — regardless of how many regulated activities the representative conducts, only one fee applies (the higher tier if multiple tiers are involved)
Fees are non-refundable, even if the representative's appointment is ceased during the year
Late payment may result in MAS enforcement action or suspension of the representative's appointment
The principal (employer) is responsible for payment, not the individual representative

Payment Process¶

MAS issues fee notices in January via CoRe
The principal reviews the list of active representatives and corresponding fees
Payment is made through CoRe (corporate credit card or authorized bank account)
Confirm payment and retain the receipt for audit purposes

Annual Fit and Proper Re-Declaration¶

Purpose¶

MAS requires principals to confirm annually that each appointed representative continues to meet the Fit and Proper criteria set out in FSG-G01. This is not a full re-assessment from scratch — it is a confirmation that no material changes have occurred that would affect the representative's fitness and propriety.

What Must Be Assessed¶

Criterion	What to Check
Honesty, integrity, and reputation	Any new criminal convictions, regulatory actions, or disciplinary proceedings
Competence and capability	CMFAS modules remain valid; CPD requirements met
Financial soundness	Any new bankruptcy filings, judgment debts, or adverse credit events
Conflict of interest	Any new directorships, shareholdings, or dual appointments

Process in Regnify¶

Step 1: Compliance Officer initiates the annual review cycle (January-March) - Generate the list of all active representatives from the MAS register - Cross-reference with Regnify's active declarations (status = MAS_APPROVED)

Step 2: Representative self-declaration - Each representative confirms whether any material changes have occurred since the last declaration - If no changes: simple confirmation is sufficient - If changes exist: the representative must disclose details

Step 3: Compliance Officer review - Review each self-declaration - For representatives with disclosed changes, conduct a targeted re-assessment - For representatives with no changes, confirm and record the annual declaration

Step 4: Record and file - Record the annual Fit and Proper confirmation in Regnify - Maintain documentation for MAS inspection (MAS may request evidence of annual reviews)

Triggers for Immediate Re-Assessment (Outside Annual Cycle)¶

The following events trigger an immediate Fit and Proper re-assessment, regardless of where you are in the annual cycle:

Trigger	Required Action	Timeline
Criminal charge or conviction	Immediate re-assessment; notify MAS if material	Within 14 days
Bankruptcy filing or petition	Immediate re-assessment; likely cessation required	Within 14 days
Regulatory action by any authority	Immediate re-assessment; notify MAS	Within 14 days
Adverse media or public complaint	Internal review; assess materiality	Prompt
Change in regulated activities	Re-verify CMFAS coverage; may need new Form 3A	Before activity change
Termination from another principal	Verify circumstances; assess impact on F&P	Before or upon hiring

Notification to MAS¶

If the annual review or an immediate re-assessment reveals that a representative no longer meets Fit and Proper criteria: 1. Cease the representative's appointment immediately 2. Submit a cessation notification to MAS within 1 business day 3. The representative must stop conducting regulated activities immediately 4. Document the reasons for cessation in the audit trail

Continuing Professional Development (CPD)¶

MAS CPD Requirements¶

Representatives must complete a minimum number of CPD hours each calendar year to maintain their competency. The specific requirements depend on the regulated activities performed.

Activity Category	Minimum CPD Hours per Year	Notes
General CMS activities	As prescribed by industry body (e.g., IBF)	Varies by activity type
Financial advisory	As prescribed by MAS Notice FAA-N26	Includes ethics component

CPD Tracking¶

What counts as CPD: - Industry conferences and seminars - Regulatory training (MAS updates, compliance workshops) - Product knowledge training - Ethics and professional conduct courses - Relevant certifications and qualifications

What does NOT count: - General business meetings - On-the-job training without structured learning outcomes - Social events labeled as "networking"

CPD Compliance Process¶

Representative: Attend qualifying CPD activities throughout the year; submit certificates and attendance records to HR
HR Administrator: Track CPD hours per representative; flag those falling behind
Compliance Officer: Review CPD compliance as part of the annual review; escalate shortfalls
If shortfall: The representative must make up missing hours before year-end; persistent shortfalls may trigger a Fit and Proper concern

CMFAS Module Renewal and Updates¶

Module Validity¶

Most core CMFAS modules (M1, M5, M6, M6A, M8, M8A, M9, M9A, M10 — retired 1 April 2024; replaced by RES/CM series under SFA04-N22 / FAA-N26) do not expire once passed; grandfathered passes under old M-codes remain valid
However, MAS may introduce new modules or update existing ones — representatives must comply with any new requirements
If a representative changes the regulated activities they perform, additional modules may be required

When CMFAS Re-Examination is Required¶

Scenario	Action Required
Representative adds a new regulated activity	Pass the corresponding CMFAS module before conducting the activity
MAS introduces a new mandatory module	Pass the module within the prescribed transition period
Representative's appointment lapsed for more than 2 years and is being re-appointed	MAS may require re-examination — check current MAS guidance
Module has been superseded by a new version	Existing pass may be grandfathered — verify with IBF

Updating Regnify After New CMFAS Passes¶

Upload the new CMFAS certificate to the representative's document repository
If the representative is adding new regulated activities, submit a new Form 3A
The new form goes through the standard internal approval and MAS submission workflow

Material Change Notifications¶

What Must Be Reported to MAS¶

The principal must notify MAS within 14 days of any of the following changes to an appointed representative:

Change Type	Notification Method
Change of name (e.g., marriage, deed poll)	Update via CoRe
Change of NRIC/FIN number	Update via CoRe
Change of regulated activities	New Form 3A submission
Change of reporting officer	Internal update; reflect in next annual review
Cessation of appointment	Cessation notification via CoRe (within 1 business day)
Adverse event (criminal charge, bankruptcy, regulatory action)	Immediate notification to MAS

Process in Regnify¶

The Compliance Officer identifies the material change
Update the representative's records in Regnify
Submit the appropriate notification to MAS via CoRe
Record the notification in the audit trail

Year-End Compliance Review¶

December Checklist¶

[ ] All active representatives have completed their annual Fit and Proper re-declaration
[ ] All representatives have met their CPD hour requirements for the calendar year
[ ] All CMFAS modules remain valid and cover current regulated activities
[ ] Annual representative fees have been paid for the current year
[ ] All material change notifications have been submitted to MAS
[ ] All cessation notifications have been submitted for departed representatives
[ ] No outstanding MAS queries remain unanswered
[ ] Documentation is complete and accessible for potential MAS inspection

Preparing for the New Year¶

Generate the list of representatives who will be active on 1 January
Calculate the annual fees payable for each representative
Schedule the annual Fit and Proper re-declaration cycle (January-March)
Review any upcoming CMFAS requirement changes from MAS
Update workflow templates if organizational changes affect the approval chain

Source References¶

MAS Guidelines on Fit and Proper Criteria (FSG-G01)
MAS Notice SFA04-N22 (Minimum Entry and Examination Requirements; superseded SFA04-N09 on 1 April 2024)
MAS Notice FAA-N26 (Competency Requirements for FA Representatives)
CMG-G01: Guidelines on Licence Applications, Representative Notification and Payment of Fees
IBF Standards for Continuing Professional Development

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