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* 1. MAS seeks comments on moving the requirements for pre-transaction
checks in FAA-G14 (paragraphs 25 to 33) to FAA-N16.

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* 2. MAS seeks comments on the proposed requirements for representatives to (i) check for and document a client’s SC status; and (ii) make a formal declaration that the assessment of whether a client is an SC has been duly performed.

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* 3. MAS seeks comments on requiring the presence of a TI for all investment recommendations made to SCs.

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* 4. MAS seeks comments on the proposed criteria for a TI.

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* 5. MAS seeks comments on the types of information that should be covered during the client call-backs and recap of the sales and advisory process, and any additional areas that should be included.

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* 6. MAS seeks comments on the proposal to require FA firms to audio record call-backs to SCs and clients of SRs.

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* 7. MAS seeks comments on whether to require call-backs and audio record of call-backs for all retail clients.

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* 8. MAS seeks comments on the proposal in paragraph 5.9, specifically on the alternative for representatives to provide a recap of the sales and advisory process at the end of the meeting/ discussion between the representative and the client, and to audio-record such a recap, in place of the proposed call-back and audio record requirement for retail clients who are not SCs and clients of SRs.

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* 9. MAS seeks views on whether FA firms should provide a copy of the audio recording to their clients and whether this should be proactively provided to clients or only on clients’ request, and how this should be operationalised.

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* 10. MAS seeks comments on the proposed requirement for an independent panel to review all product recommendations made to SCs, including the size of this panel and suitable person(s) to form this panel.

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* 11. MAS also seeks comments on whether this review by the independent panel should be conducted on a pre or post-transaction basis.

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* 12. MAS seeks views on requiring the ISA Unit to perform additional sampling and review for transactions involving higher risk clients who meet one or more of the criteria set out in paragraph 7.2, and on the proposed 10% sampling level for transactions involving such clients.

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* 13. MAS seeks comments on the transitional period of six months to implement the enhanced requirements proposed in this paper.

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* 14. CFA ID (Optional)

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