| 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. |
| Eligibility & opt-in (one screen)⚠️ with conditions |
One question — net personal assets over S$2m, yes or no. Answer yes and the opt-in box appears below on the same screen; tick it, then "Continue." PDPA purpose notice. |
The S$2m net-assets test is one of the statutory Accredited-Investor limbs; asking only it is more conservative than the full set, and a "no" means "not on this route", not "not an AI". The opt-in must be the customer's own affirmative act — never pre-ticked, defaulted, or adviser-completed — and the effect must be given before AI treatment.SFA s.4A · explicit opt-in (8 Apr 2019) · PDPA |
High, if nudgedLeading a prospect to opt in — the signature SG conduct risk. Benefit-framing, pre-selection, or adviser completion. |
Unticked by default; the customer's own tick; the loss of retail protections stated at the box, with the fuller note under "Why this matters"; a "no" ends the route with no pressure; PDPA notice at capture.Compliance to settle: the exact opt-in / disclosure wording; and that narrowing to one limb is acceptable. |
| Private-markets explainer (on "new")⚠️ with conditions |
One familiarity question; if the prospect is new to private markets, a three-minute explainer holds the private-markets ideas within each theme until watched. |
An AI needs no assessment, so this is conduct. Education to gain knowledge is a recognised route; but only the prescribed module formally counts, and private markets reach a prospect only as an Accredited Investor regardless — so the primer is conduct, not the legal key.SFA s.4A · CKA learning-module route · ss.304–305 |
MediumTreating an in-house video as a certificate, or as replacing the statutory assessment. |
An optional explainer, orientation only and never a certificate — it does not assess knowledge or change eligibility; AI status stays the access basis. Holding private-markets ideas behind it for a new prospect is the more cautious posture. |
| Current market themes (the surface)⚠️ with conditions |
A few current-market themes, each a short story with a couple of sample ideas across sleeves — explicitly "not our whole shelf." Single-line names carry a research preview; private-markets ideas open behind the primer; 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 for 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 · FAA-N16 perimeter |
MediumA theme reading as a recommendation to act; an unauthorised fund publicly promoted; the own product shown without the conflict disclosure. |
Labelled "sample ideas," balanced, no superlatives; AI-gated, never public; the "not authorised by MAS, not for the retail public" line; own-CIO interest disclosed; illustrative, not advice; an audit trail.Compliance to settle: the own-product disclosure-and-controls package. |
| Profile✅ approve |
The prospect's capture status and Accredited-Investor status. |
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. |