| Home & the locked portal✅ approve |
The opening question, a locked Solutions tab, and a note from the adviser. No product specifics before the gate. |
Pre-unlock content is generic and non-customised, so it stays on the illustrative side of the recommendation-and-offer line; the locked tab gates the product-specific surface.Illustrative-vs-solicitation line · FAA-N16 perimeter |
LowThe adviser's note tipping into a specific recommendation to this prospect. |
Keep the note non-directed; gate all product specifics; log the deliberate click as customer-initiated interest — corroborating evidence, not the legal basis. |
| Intro & markets✅ approve |
Why we ask; ~2 minutes; nothing here is a transaction; which markets are familiar. PDPA purpose notice. |
Capturing knowledge and experience is permitted; before collecting it the purpose must be stated and consent obtained. "Which markets" is context, not an assessment.PDPA — notification & consent at capture |
LowCollecting data without a purpose notice or consent. |
Show the PDPA purpose notice and consent at the point of capture; collect only what the unlock needs. |
| Investor status — the fork⚠️ with conditions |
An eligibility basis (or "none of these apply") and an unticked, optional opt-in, with the effect-of-opting-in stated: you would be treated as an Accredited Investor and give up certain retail protections. Declining still opens equities, bonds and research. |
AI status is the decisive fork — an AI is exempt from the assessment, and alternatives are AI-only, so establishing it early is sound. The opt-in must be the customer's own affirmative act, never pre-ticked, defaulted, or completed by the adviser; the effect-of-opt-in disclosure precedes it.SFA s.4A · explicit opt-in (8 Apr 2019) · ss.304–305 |
High, if nudgedForegrounding the opt-in as "the key to everything" leads the prospect — the signature SG conduct risk. The genuine non-AI path is what holds this to Medium in practice. |
Opt-in unticked and the default is retail (you must actively choose AI); neutral copy, never "most clients opt in"; the effect-of-opt-in disclosure shown; a real retail path that delivers EIP content and research.Compliance to settle: the exact prescribed AI-treatment disclosure wording. |
| AI path — experience✅ approve |
For an Accredited Investor: years in the markets, traditional familiarity, and which alternatives have been held — only for the markets they chose. |
An AI is exempt from the Customer Knowledge Assessment, so this is context and conduct, not an assessment. "Held / not held" is not a CKA limb and is not billed as one.SFA s.4A · held/not-held is not a CKA limb |
LowPresenting the macro capture as a completed knowledge assessment. |
Labelled explicitly as context, never a knowledge assessment; it only decides whether to offer a primer. |
| Alternatives primer (on "have not")⚠️ with conditions |
Only when an AI is new to a private-markets category: an optional three-minute primer holds those ideas until watched. |
An education route to knowledge is recognised — the CKA learning-module path can satisfy a knowledge limb for a retail prospect. But only the prescribed module formally counts, and alternatives reach a prospect only as an Accredited Investor regardless of knowledge — so the primer is a knowledge and conduct step, not the legal key.SFA s.4A · CKA learning-module route · ss.304–305 |
MediumTreating an in-house video as a certificate that unlocks AI-only product or replaces the statutory assessment. |
An optional primer recorded to the profile, never a regulatory certificate; AI status stays the access basis; not tied to the opt-in. Holding the ideas behind it for an inexperienced prospect is the more cautious posture.Compliance to settle: whether an in-house primer can count toward formal CKA, or only the prescribed module. |
| Retail path⚠️ with conditions |
Decline the opt-in and equities, plain bonds and research are open; fund ideas open after one real knowledge-check limb (qualification / 3yrs work / 6+ transactions / the prescribed short course); alternatives are not available. |
Single equities and plain bonds are Excluded Investment Products — no test. Specific fund (SIP) content for a retail prospect needs one satisfied CKA limb; held/not-held cannot substitute. Alternatives reach a prospect only as an Accredited Investor, so they are not shown.EIP/SIP · CKA limbs (SFA 04-N12 / FAA-N16) · ss.304–305 |
MediumShowing specific SIP fund content to a retail prospect with no CKA; or held/not-held standing in for the CKA. |
EIP and research open; fund ideas gated behind a genuine CKA limb with annual review; alternatives locked, stated factually with no CTA to opt in (status changeable only by the prospect, in Profile).Compliance to settle: whether an in-house course can count toward the formal CKA, or only the prescribed module. |
| Unlock & the surfaces⚠️ with conditions |
AI: the full shelf (alternatives primer-gated where new). Retail: equities, bonds and research, funds behind the check, alternatives locked. Includes the firm's own CIO funds. |
For an opted-in AI, fund and restricted-scheme content is permitted, scoped to AI-only and clearly identified. Unauthorised funds must state they are not authorised or recognised by MAS and not offered to the retail public, and must not be publicly promoted. Own products are house-view output, interest disclosed. No advisory verbs.SFA ss.286 / 287 / 304–305 · surface language rules |
MediumPublic promotion of an unauthorised fund; the own product shown without the conflict disclosure; the surface reading as advice to act. |
AI-gated, never public; the "not authorised by MAS, not for the retail public" line on those funds; own-product interest disclosed and presented evenly; illustrative, not advice; an audit trail.Compliance to settle: the own-product disclosure-and-controls package. |
| Profile✅ approve |
The prospect's K&E status and investor status (Accredited Investor or retail). |
The prospect can see and correct the data held; the surface must not show identification or financial detail beyond what the unlock requires.PDPA — access/correction · PII discipline |
LowSurfacing more personal data than needed. |
Minimal personal data; access and correction; retention scoped. |