Since 29 December 2025, the Monetary Authority of Singapore (MAS) has required financial advisers — including life insurers and their representatives — to identify “Selected Clients” during know-your-client, under the amended MAS Notice FAA-N16. A client who fails at least two of three tests (age under 62, language proficiency, education) must be accompanied by a trusted individual or sign a waiver, and their transaction needs a documentation review and an audio-recorded call-back before the policy takes effect. Every one of those steps leaves evidence on the file — and every one can be audited.
Most of the conversation about MAS’s December changes has been about call-backs and pre-transaction checks. The part I think deserves more attention is the step that decides which clients get the extra protection in the first place. If the Selected Client test is wrong, or undocumented, everything that follows in the file is built on sand.
Nine months into the new rules, here is what the test requires, what has to follow from it, and where I would expect files to fail.
Who is a Selected Client?
Under paragraph 10A of FAA-N16, a financial adviser must establish three things as part of know-your-client:
1. Whether the client is under 62 years of age.
2. Whether the client is proficient in spoken and written English — or in the other language the sale is conducted in and the documents are written in.
3. Whether the client has at least GCE ‘O’ Level or ‘N’ Level certifications, or equivalent academic qualifications.
If at least two of the three are answered “no”, the client must be treated as a Selected Client.
There is one way out. Under paragraph 10B, the adviser may decide not to treat the client as a Selected Client if it has reason to conclude the client has adequate knowledge and experience in a class of investment products — and the recommendation is limited to that class.
Either way, paragraph 10C requires the adviser to document the determination, including the reasons for any 10B override, and to declare that it has done so. That record is the foundation of everything else.
What has to happen for a Selected Client?
A trusted individual, or a waiver (paragraph 10D). The sales process cannot proceed unless the Selected Client is accompanied by a trusted individual who is 21 or older, proficient in the language of the sale, holds at least GCE ‘O’ or ‘N’ Level or equivalent, and can communicate effectively with the client. The client’s consent for that person to see their personal information must be documented. Alternatively, the client can give a written statement declining a trusted individual and confirming they are fully able to make decisions alone.
A documentation review before the policy takes effect (paragraph 41K(a)). Every document required under the notice is reviewed to verify the non-sales KPIs were met, including know-your-client and needs analysis.
An audio-recorded call-back (paragraphs 41K(b) and 41S). Unless the representative’s supervisor was present for the entire sales process, the firm must call the client back and record it. The call must test whether the client understands the basis for the recommendation, the product’s main features, key risks and limitations, and the free-look period for a life policy. For a Selected Client it must also confirm they were offered a trusted individual, and that one was present — or that they can decide without one. And it must check the representative behaved professionally and ethically.
Exceptions and records (paragraphs 41T and 41U). If a call cannot be recorded — for example, the client refuses — a written summary with the questions, answers and the reason must be acknowledged by both the client and the person making the call, and the firm needs controls to stop recording being avoided. Recordings or summaries are kept for at least five years, and the client can ask for a copy or transcript.
The same call-back requirement applies to clients of “Selected Representatives” — representatives graded B or worse under the Balanced Scorecard for two consecutive quarters.
Where are files most likely to fail?
From years of reading insurance files, these are the gaps I would look for first. They are my view of the practical risks, not findings MAS has published.
• Half a test. Age is captured automatically from the client’s details; language and education are left blank or ticked by default. The determination looks complete but was never really made.
• An override without reasons. The 10B exception is used — the client “has experience” — but the file does not say what experience, or the recommendation goes beyond the class of products it covers.
• A trusted individual who does not qualify. A family member attends, but nothing on file shows they are 21 or over, proficient in the language or educated to the required level — or the client’s consent was never documented.
• A waiver that is really a form. The client’s statement declining a trusted individual is pre-printed and signed at the end of a long pack, with nothing showing it was their decision.
• A call-back that asks the wrong questions. The recording exists, but it skips the free-look period or never tests whether the client understood the risks — or the client’s answers show they did not, and the policy proceeded anyway.
• A supervisor who was “present”. The call-back is skipped because a supervisor attended, but nothing shows they were there for the entire sales process.
What to check in every Selected Client file
1. All three 10A questions answered, with evidence, and the determination documented and declared.
2. Any 10B override explained, and the recommendation limited to the stated product class.
3. A trusted individual who meets all four criteria, with the client’s consent on file — or a genuine written waiver.
4. A documentation review completed before the policy took effect, covering the four non-sales KPIs.
5. An audio-recorded call-back covering every required question — or a compliant written summary with the reason recording was not possible.
6. Call-back answers that show the client understood; any sign they did not, followed up before the policy started.
7. Records kept for five years, retrievable when a client asks.
At the volumes Singapore’s larger insurers write, checking this by hand in every file is a significant workload. FAA-N16 allows documentation reviews to be performed by a computerised system if the firm can show it is effective (paragraph 41N) — which makes Selected Client checks one of the clearest candidates for automation: the rules are precise, the evidence is on the file, and the reasoning can be recorded.
Why it matters
The Selected Client rules exist for the clients most likely to be harmed by an unsuitable sale. The protections only work if the first step — identifying who needs them — is done properly and can be proven. That is where I would focus any audit this year.
At Curium, our Agent Oversight product audits these checks on every file, alongside the rest of FAA-N16 and the Balanced Scorecard KPIs. But whatever tools firms use, I would be interested in how others are handling it: where are you seeing Selected Client files fall short? Learn more about Curium’s compliance solutions.
Tetiana George is CEO and Co-founder of Curium and Co-Chair of Insurtech Australia. She is based in Singapore.
References
• MAS Notice FAA-N16 — Recommendations on Investment Products, Monetary Authority of Singapore
• MAS Notice FAA-N16 (Amendment) 2025, tracked changes, issued 29 December 2025, Monetary Authority of Singapore — paragraphs 10A–10E, 41K, 41N and 41S–41U
• MAS revised notices and guidelines to enhance pre- and post-transaction safeguards for retail clients, Allen & Gledhill
• Notices, guidelines and FAQs for financial advisers revised to implement enhanced transaction safeguards, Rajah & Tann Asia
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Author:
Tetiana George, CEO of Curium, Co-Chair of Insurtech Australia and member of ASIC Digital Finance Advisory Committee. LinkedIn Profile.