Generally, an applicant must undergo a formal process involving the completion of required application forms and the submission of supporting information. While there may be estimated timelines, this is not determinative and there is no time frame within which the MAS must consider and decide on an application; moreover, this may vary depending on the bandwidth of the relevant MAS officers. The particular forms that must be completed for submission to the MAS will depend on the nature of the regulated activities to be conducted. The requisite forms (if any) may be found on the MAS website.

For an applicant to carry out regulated activities in the financial industry, such as capital markets services or financial advisory services, the following forms are broadly required:

• License Application Form - This form sets out information about the applicant, its proposed business activities, organizational structure, shareholders and directors.
• Individual Forms -   An applicant will also have to submit forms providing information about individuals to be appointed as representatives, chief executive officers and directors. The applicant will have to certify that it is satisfied that such individuals are fit and proper.
• Supporting documents -   Various documents, such as business plans, organization charts and recent audited financial statements, must be submitted with the forms set out above.
• Letter of responsibility or undertaking – In some cases, the MAS may require the applicant to procure a letter of responsibility or undertaking from its parent company, which commits the parent company to maintaining adequate oversight over the applicant or to undertaking liability if the applicant fails to maintain certain liquidity or financial requirements.

Specific documents or information may also be required, depending on the type of license applied for and the regulated activity intended to be carried out. For instance, an application for a license under the Payment Services Act 2019 that seeks to cover DPT services may need to be accompanied by a legal opinion on the token in question and a completed Technology Risk Questionnaire to verify the technological readiness of the applicant.

Fintech

The MAS has a fintech regulatory sandbox, which enables financial institutions and fintech players to experiment with innovative financial products or services in a live environment but within a well-defined space and duration. There could therefore already be licensed financial institutions expanding the scope of their activities or new market entrants looking at obtaining a license. Depending on the experiment, the MAS will provide the appropriate regulatory support by relaxing specific legal and regulatory requirements prescribed by the MAS, which the sandbox entity will otherwise be subject to, for the duration of the sandbox. The sandbox will include appropriate safeguards to contain the consequences of failure and maintain the overall safety and soundness of the financial system.

Upon successful experimentation and on exiting the sandbox, the sandbox entity must fully comply with the relevant legal and regulatory requirements. There are three sandbox options: (i) sandbox for more complex business models where customization is required to balance the risks and benefits of the experiment; (ii) fast-track approvals for activities where the risks are low and well-understood by the market; and (iii) one-stop assistance in areas of regulatory support and financial grant. To be clear, it is also possible for fintech players to apply for the relevant licenses under the standard license application process without having to go into the sandbox if there is no intention to test products within the sandbox.