Start by defining your business model. Having this documented will make the application process so much smoother as there is nothing of value you can claim to being a “fintech company” or “financial platform.” Read here to see recent information!
Describe your service in detail.
Will they use your platform to send or receive money?
Will it hold funds?
Will it manage investment funds?
Will it arrange payments?
Will it be dealing with capital markets products or digital payment tokens?
Detail what they will do for each one of the function mentioned. The whole process will be better structured if it can be tracked like the one describing a whole journey of a customer from creating account and eventually making the payment transaction and indicating in where and how does money flow. Indicate the kind of systems and decisions the company is taking.
From that exercise it will be very easy for your team to quickly see the concern points regarding your regulation.
Regulate services according to your own business activity. It is very important you make sure that whatever services your company provides fit into MAS’s respective regulatory framework. Regulations vary for each of the service being performed as the authority categorizes businesses.
Do not follow the regulations of another similar company applying for a similar license to your business. This is because not all regulations that fit into an other company’s business might apply in to yours. Software services could lead to regulation very different compared to money handling services for example. Money handling carries responsibilities that could affect the entire company in a more direct way then those for pure technology software solutions.
Outline ownership and governance. The owner(s) and controller(s) of the company applying for theMAS license Singapore, should be laid out accurately along with the directors, board of directors members, senior members in the management ranks, other members, relevant companies related and the main stakeholders together. Should the business be a subdivision within a larger corporation, there are required explanations along with the reasons why the company has a designated structure for different organizational units. Management roles for instance, such as those of risk management officers or internal directors etc should be detailed as needed, and who are the officers with the responsibility:
Who manages risk?
Who controls quality on the operations and develops improvements procedures?
Who takes control over the day-to-day administrative functioning of the company together with the authority over its direct operations? The answers will let them create an appropriate picture of the corporation functioning structure, provided it is granted approval.
Propose procedures applicable to employees. Having an employee manual containing operational policies covering the handling of client funds, AML processes, due diligence in terms of Know Your Customer requirements and, in case such procedures would require it to do so, client verification under screening rules applied for transaction monitoring or checking unusual movements of funds from either customers accounts or from other sources, as well as regulations on record keeping of client transactions and what should be done in case of customer complaints and suggestions should be clear in an operative way and realistic. Employee knowledge for example, in a situation where a payment is viewed suspicious within the system, how one should assess, forward and address the alert, the required staff and the reporting that must be performed at management level is very important. Vague descriptions or even hypothetical situations are not well- received by MAS representatives and can easily result into delays.
Technology and cybersecurity are of key importance. Many services related to financial business operation depend on an advanced technology framework; therefore it is imperative that the information security policy covers aspects relating to the users’ data and information security levels along with monitoring standards for maintaining effective performance. Recovery arrangements must already be defined within the plan that aims at dealing with unpredictable circumstances like cyber threats, IT disasters or system failures. Responsibility is needed for important technology vendors as well as for each relevant aspect they might cover.
Draft your cash flow forecast. The forecast must depict all realistically achievable projections associated with the operation and should indicate the projected revenue generated from sales, the planned expenditures (including staff and technological operations) together with general running costs and relevant professional fees. If relevant you should estimate the operating capital which is required to start the service. Unrealistic projections are disadvantageous.
Finally: the last stage before sending in the application to MAS would be that your team will thoroughly review it. During the follow-up MAS authorities can question, request and seek for further clarifying documentation. It’s essential to ensure the application details have consistency regarding the financial status, organizational structure and processes in place with regard to the overall business plan of the venture.
Having a clear MAS license Singapore application will make it easier for authorities to have a picture of the operation and might prevent them from encountering or pointing out any areas that are insufficient within your system.