This course provides a foundational, regulatory-focused deep dive. It is ideal for professionals who need to understand the core principles, legal obligations, and governance structures mandated by MAS.
Target Audience
Portfolio/Fund/Investment Managers; Execution Trader; and Financial Planners.
Course Objectives
Upon completing this course, you will be able to:
- Define outsourcing and materiality in the context of the Singapore financial sector.
- Identify the key MAS Notices and Guidelines governing outsourcing and their legal weight.
- Explain the non-delegable responsibilities of the Board and Senior Management.
- Describe the mandatory requirements for due diligence, ongoing monitoring, and independent audits.
- Articulate the specific rules for safeguarding customer information, especially in sub-contracting arrangements.
Course Outline
Module 1: Introduction to Outsourcing in Singapore's Financial Sector
- What Constitutes an "Outsourced Relevant Service".
- The Concept of "Materiality" and its Impact.
- Key Definitions: Service Provider, Sub-Contractor, Customer Information.
- The "Why": Understanding MAS's Focus on Systemic and Reputational Risk.
Module 2: The MAS Regulatory Landscape
- The Shift from Guidelines to Legally Binding Notices (repeal of 634/1108, introduction of 658/1121).
- Scope of Application: Banks, Merchant Banks, and Other Financial Institutions.
- Interplay with Other Key Regulations: TRM Guidelines, Notice on Cyber Hygiene, Banking Act (Section 47).
- Overview of the Outsourcing Register Requirement.
Module 3: Governance and Accountability: The Buck Stops Here
- The Role of the Board and Senior Management in Oversight.
- Establishing a Group-Wide Outsourcing Risk Management Framework.
- Defining Risk Appetite and Approval Authorities.
- Proving Accountability: Why You Can Outsource the Function, But Not the Risk.
Module 4: Core Lifecycle Requirements: Due Diligence and Audits
- Initial Due Diligence: Assessing a Vendor's Risk Framework, Reputation, and Financial Strength.
- Ongoing Monitoring: Frequency and Scope (Within 24 Months and Ongoing).
- Independent Audits: The "At Least Once Every Three Years" Rule for Material Arrangements.
- Understanding and Leveraging "Pooled Audits" (e.g., OSPAR Reports).
Module 5: Safeguarding Customer Information: The Critical Mandate
- MAS's Stance on Confidentiality and Data Protection.
- The Critical Consent Requirement for Sub-Contracting Arrangements Involving Customer Data.
- Measures for Protecting Data in Cross-Border and Cloud Arrangements.
- Requirements for Data Destruction or Rendering Data Unusable Upon Termination.