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There are total twenty (20) questions / comments (do not need to answer all questions) but justification and explanation appreciated.

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* 1. Question 1:

MAS seeks comments on the proposed definition of transition planning.

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* 2. Question 2:

MAS seeks comments on the proposed context for the TPG as laid out in paragraph 1.3 of the TPG.

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* 3. Question 3:

MAS seeks comments on whether the drafting of paragraph 1.3 (d) of the TPG on factoring in the climate-nature nexus accords asset managers with sufficient flexibility to improve their understanding of other environmental-related risks and risk management processes over time. What are some tangible areas regarding other environmental-related risks (e.g. vulnerability on water availability) that you would see value in having elaboration in the guidance?

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* 4. Question 4:

MAS seeks comments on the entities and business activities that are in the proposed scope of the TPG.

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* 5. Question 5:

MAS seeks comments on the proposed expectations on governance and strategy as laid out in paragraphs 2.1 to 2.3 of the TPG.

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* 6. Question 6:

MAS seeks comments on the proposed approach to portfolio management as laid out in paragraphs 3.1 to 3.3 of the TPG.

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* 7. Question 7:

MAS seeks comments on the proposed expectations on the use of forward-looking tools for portfolio management as laid out in paragraphs 3.4 and 3.5 of the TPG.

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* 8. Question 8:

MAS seeks comments on the proposals set out in paragraphs 3.6 to 3.9 and paragraph 3.12 of the TPG, particularly in relation to the expectations around setting of decarbonization targets by asset managers.

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* 9. Question 9:

MAS seeks views on the proposed required attribution process set out in paragraph 3.10 of the TPG, including any practical constraints that asset managers may face.

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* 10. Question 10:

MAS seeks views on whether it would be useful to specify broad categories for attribution referenced in paragraph 3.10 of the TPG, and if so, what such categories could include.

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* 11. Question 11:

MAS seeks views on whether the drafting in paragraph 3.11 of the TPG will allow asset managers to support climate positive outcomes. Please also highlight if there are other considerations to include in the drafting to ensure that these are done in a credible manner and not used as a means of transition washing.

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* 12. Question 12:

MAS seeks views on whether paragraphs 3.13 to 3.15 of the TPG provide an adequate overview of the people, processes and systems necessary for a robust implementation of asset managers’ transition planning.

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* 13. Question 13:

MAS seeks comments on the proposed guidance on engagement and stewardship as laid out in paragraphs 4.1 to 4.8 of the TPG.

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* 14. Question 14:

MAS seeks views on whether paragraph 5.1 of the TPG should reference other reporting frameworks.

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* 15. Question 15:

MAS seeks views on whether paragraphs 5.1 to 5.3 of the TPG set out the key aspects necessary for market transparency.

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* 16. Question 16:

MAS seeks views on whether paragraphs 5.1 to 5.3 of the TPG provide sufficient additional guidance (i.e. in addition to existing expectations in paragraphs 7.1 and 7.2 of the ENRM Guidelines) for asset managers to disclose information related to their response to material climate-related risks and governance around processes for addressing such risks.

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* 17. Question 17:

MAS seeks views on the proposal in paragraph 5.3 of the TPG for asset managers to consider the use of taxonomies in product-level disclosures, including the suitability of including GFIT’s Singapore-Asia and ASEAN taxonomy as examples. For instance, would such suggestions restrict or support asset managers’ transition financing activities?

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* 18. Question 18:

MAS seeks views on the cited areas of disclosure under paragraph 5.4 of the TPG (i.e. factors, inputs, methodologies, material assumptions and dependencies underlying its disclosures), such as whether there are any practical constraints or competitiveness concerns in providing such disclosures.

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* 19. Question 19:

MAS seeks suggestions of other examples of transition planning practices currently implemented by asset managers that could be incorporated in the TPG.

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* 20. Question 20:

MAS seeks comments on the proposed implementation approach, including the proposed transition period of 12 months.

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* 21. CFA ID (Optional)

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* 22. Please fill in your particulars below:

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* 23. I wish to keep the following confidential (Optional):

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