| 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. |
| K&E intro & data notice✅ approve |
“A few questions, around two minutes. Nothing about finances.” |
Capturing knowledge and experience is permitted; before collecting it, the purpose must be stated and consent obtained.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. |
| Steps 1–3 — experience✅ approve |
Which markets are familiar (traditional / alternatives), years in the markets, and which alternatives have been held. |
For the Accredited-Investor route this is not even legally required — AIs are exempt from the knowledge assessment. For a retail prospect it is lighter than, and not a substitute for, the statutory CKA. Single equities and plain bonds need no test; alternatives are gated to AIs.SFA s.4A · SFA 04-N12 / FAA-N16 · ss.304–305 |
Low–MedTreating this macro capture as a completed knowledge assessment, or as suitability. |
Framed as experience flavour, not a knowledge assessment or suitability; minimal data; for any retail prospect the real CKA limb is still required before an unlisted product. |
| Alternatives primer (optional)⚠️ with conditions |
For a prospect newer to private markets, an optional three-minute primer; once watched, the alternatives ideas open. |
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; or using it to nudge toward the opt-in. |
Framed as an optional primer recorded to the profile, never a regulatory certificate; Accredited-Investor status stays the access basis for alternatives; the primer is 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. |
| Step 4 — Accredited-Investor eligibility & opt-in⚠️ with conditions |
An eligibility basis (over S$1m financial assets, S$300k income, or over S$2m net assets) and an explicit, unticked opt-in to be treated as an Accredited Investor. |
The thresholds match the statutory definition. The opt-in must be the customer's own affirmative act — never pre-ticked, defaulted, or completed by the adviser. Eligibility is customer-declared and firm-verified; prescribed written disclosures precede AI treatment.SFA s.4A · explicit opt-in from 8 Apr 2019 |
High, if nudgedLeading a prospect to opt in as an Accredited Investor — the signature Singapore conduct risk. Failure modes: benefit-framing, pre-selection, or adviser completion. |
The opt-in is a fresh, unticked, customer-only action, reset on every run; the adviser cannot complete it; copy is neutral, never “most clients opt in”; eligibility is evidenced.Compliance to settle: the exact prescribed AI-treatment disclosure wording. |
| Step 5 — summary & confirm✅ approve |
“What we heard,” then the record is kept to the profile and used only to decide what may be shown. |
The K&E data may be used only for the purpose stated at capture.PDPA — purpose limitation |
LowRe-using K&E data for unrelated marketing, or keeping it too long. |
Purpose-limited use; retention scoped to the record-keeping rationale; access and correction available. |
| Unlock & the implementation surface⚠️ with conditions |
Illustrative ideas across equities, fixed income and alternatives — including the firm's own CIO funds — with a research preview. |
For an opted-in Accredited Investor, fund and restricted-scheme content is permitted, scoped to AI-only material 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. The firm's own products are house-view output, but the interest must be disclosed. No advisory verbs.SFA ss.286 / 287 / 304–305 · surface language rules |
MediumPublic promotion of an unauthorised fund; the firm's own product shown without the conflict disclosure or visually weighted; 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; the own-product interest disclosed and presented evenly, no superlatives; illustrative, not advice; an audit trail of what was shown.Compliance to settle: the own-product disclosure-and-controls package. |
| Profile✅ approve |
The prospect's K&E 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. |