Regulation · what we may show a prospect, by asset class
What we may show a prospect, before they are a client.
We are giving a prospect a flavour of what our strategy team is watching, across equities, bonds and alternatives — not advice, and not a recommendation. For each market we set out four things: what the regulation says, the disclosure the prospect sees, the residual risk, and the controls around it. Three markets — Singapore, Hong Kong and the UK — verified at source and re-checked with a second model.
What we can show, by asset class
Start with the asset, not the questionnaire.
The lighter the product, the less we need to capture. Single-line equities and plain bonds are the simplest; funds and alternatives carry conditions, and in Singapore the Accredited-Investor opt-in lifts them.
| Asset class | SingaporeMAS | Hong KongSFC | United KingdomFCA |
|---|---|---|---|
| Single-line equities | ✅ Excluded Investment Product — no knowledge test, even for a retail prospect. | ✅ Traditional asset; factual material needs no K&E. | ✅ Non-complex — no appropriateness test. |
| Plain bonds | ✅ Excluded Investment Product — no test. Structured notes are the exception. | ✅ Traditional; structured notes are complex products. | ✅ Plain vanilla non-complex; structured is complex. |
| Funds (equity & bond funds) | ⚠️ A fund can fall either side of the line. Where it is a Specified Investment Product, retail needs one knowledge limb; an Accredited Investor is exempt either way. | ⚠️ Authorised funds can be non-complex; complex or derivative funds carry warnings. | ⚠️ Non-complex funds need nothing; complex funds attract the appropriateness test. |
| Alternatives PE · private credit · real assets · hedge funds | ⚠️ Not for the retail public. They reach a prospect only as an Accredited Investor, offered privately, not publicly promoted. | ⚠️ Not automatically “complex.” Unauthorised funds are Professional-Investor-only; if it is a derivative, a knowledge characterisation applies and is never waived; if complex, Chapter 6 warnings apply. | ⚠️ Generally complex — a genuine appropriateness test at the transaction step, and some carry separate financial-promotion restrictions. |
✅ showable with no knowledge step · ⚠️ showable with a condition stated below. The discipline that holds across all three: the unlock frees the interaction, not the content — the surface stays factual and balanced.
01 — Where the prototype is built
Singapore · MAS
The proposal
In Singapore an Accredited Investor is exempt from the knowledge assessment, so where a prospect makes that election for themselves, the opt-in is the only knowledge step. It must be their own affirmative act, never led by the adviser.
An Accredited Investor is exempt from the knowledge assessment. Single-line equities and plain bonds are Excluded Investment Products and need no test even for a retail prospect; a complex fund is a Specified Investment Product needing one knowledge limb for retail, but not for an AI. Alternatives are not offered to the retail public — they reach the prospect only as an AI, through the restricted-scheme route, which permits a private offer but no public advertising.
SFA s.4A · MAS Notice SFA 04-N12 / FAA-N16 para 16 · SFA ss.304–305The opt-in itself is the disclosure the prospect makes, and it must be their own affirmative act.
“I meet the Accredited Investor criteria and choose to be treated as one. I understand that some material is for Accredited Investors only, that certain funds are not authorised by MAS, and that they are not offered to the retail public.”
Low The one way this goes wrong is advertising a MAS-unauthorised fund to the public instead of offering it privately to the Accredited Investor. The restricted-scheme route forbids public promotion, even to AIs.
- The opt-in is the prospect's own tick, never pre-filled or completed by the adviser.
- Unauthorised funds sit behind the AI gate; no public “fund of the month.”
- Every alternatives surface carries the line: not authorised by MAS, not for the retail public.
- The capture stays minimal, with the purpose stated at the point of collection (PDPA).
02
Hong Kong · SFC
The proposal
For the Individual Professional Investor, factual and balanced material needs no knowledge step at all. We add a derivatives check only where the product is actually a derivative, and we keep alternatives behind the Professional-Investor gate.
Posting factual, fair and balanced material is not a solicitation and triggers no K&E: “the posting of factual, fair and balanced product-specific materials would not in itself amount to a solicitation or recommendation and will not trigger the Suitability Requirement.” An “alternative” is not automatically a complex product. Three distinct gates can apply: most are unauthorised funds, which are Professional-Investor-only regardless of complexity; where the product is a derivative, the firm must assess and characterise the client's derivatives knowledge, “not relying merely on the client's declaration,” and that is never waived for an individual; and where the product is complex under Chapter 6, minimum-information and warning-statement duties attach.
SFC Online Distribution Guidelines para 5.3, 2.2(i) · Code of Conduct 5.1A · para 6.11“This material is for information only. It is not a solicitation or a recommendation. Some products are available only to Professional Investors. Some complex products, including certain derivatives, can lose more than the amount invested.”
Low for traditional and factual material. Medium on derivatives. It goes wrong if a bare prospect tick stands in for derivatives knowledge, or if the surface is weighted toward specific products so that balanced material reads as a sales pitch.
- Derivatives knowledge is captured as an adviser-evidenced record, not a one-click toggle.
- Alternatives sit behind Professional-Investor status; unauthorised funds are never shown to the unscreened public (para 2.2(i)).
- The strategy surface carries disclosed, objective selection criteria (para 2.3(v)) and stays factual and balanced, never product-weighted.
The one hard line
Derivatives knowledge must be gathered by the firm, “not relying merely on the client's declaration.” A bare checkbox is insufficient, and it is never waived for an Individual Professional Investor.
SFC Code of Conduct para 5.1A · Online Distribution Guidelines para 6.11.
03
United Kingdom · FCA
The proposal
We show factual, published views to any prospect, and add an appropriateness check only when a prospect moves to transact in a complex product — at the door from prospect to client, not at the moment of viewing.
Showing factual information does not by itself trigger appropriateness: “only communications with a degree of incitement are inducements; purely factual information is not.” So a prospect can be shown published views with no test. The appropriateness duty — assessing a client's knowledge and experience, and showing an interrupting warning if a complex product is not appropriate — attaches only when someone moves to transact. That sits at the transaction step, after onboarding, not at the prospect stage this portal covers.
PERG 8.4 · COBS 10A.4 · COBS 10A.2.2 / 10A.3At the prospect stage the disclosure is just the published-view framing: a view, not advice, and not assessed for you. Nothing is transacted here, so the appropriateness warning does not arise — it belongs at the later transaction step, after onboarding, and is not part of this portal.
“This is a published view from our strategy team. It is not advice, and it has not been assessed as suitable or appropriate for you. Anything you act on would come later, once you are a client.”
Low at the prospect stage — only published views are shown, and nothing is transacted. The risk is one the later transaction step has to handle: a one-click “I understand” dropping straight into “confirm and transact,” the exact pattern the FCA named in its CFD review. That control is designed in when transacting is built, after onboarding.
- At the later transaction step, the complex-product warning interrupts and is not immediately followed by a transact button — not a control this prospect-stage portal needs.
- The strategy surface is a published view, balanced with comparators and downside, kept outside personal-recommendation territory (COBS 9A).
- A macro attestation weighted to profession and history, not a per-instrument grid.
- Document the lawful basis and retention for prospects who never onboard (UK GDPR Art 6).
The one hard line
When transacting is later built, the complex-product check must be genuine: “risk warnings should be designed to interrupt the application process,” and “applicants should not be asked to confirm an intention to proceed with a transaction as the next step.” This portal stops short of that step.
FCA multi-firm review — CFD appropriateness assessments, 29 June 2017.
The question you raised
Can we put our own CIO product in front of a prospect?
Yes, with conditions — and it helps to separate two things that both sit on the surface. The CIO funds are the private bank's own strategies, including the mutual-fund version of the CIO multi-asset, so the interest is genuinely ours and has to be made plain. The asset-management funds sit on an open shelf alongside many third-party managers; we show them because our conviction is there, not because we want a prospect to buy them. Both are allowed as house-view output. What we cannot do is let a prospect mistake our own CIO fund for a neutral view.
The firm has a financial interest in its own products, and that interest has to be managed and, where it matters, disclosed. The UK is clearest: own products can be shown as long as the conflict is managed (SYSC 10), the material stays fair, clear and not misleading (COBS 4.2), and the outcome is good for the customer (Consumer Duty, PRIN 2A). Hong Kong reaches the same place by principle — honesty and fairness, plus disclosed objective selection criteria for a curated list (Guidelines para 2.3(v)). Singapore reaches it through the financial-adviser conflicts framework. The exact own-product disclosure-and-controls package in HK and SG is a Compliance sign-off item, not settled here.
UK: SYSC 10 · COBS 4.2 · PRIN 2A.5 · HK: Guidelines 2.3(v), 5.3 · SG: FA conflicts framework — to confirm“Some of the strategies shown here are JPC's own. We have a financial interest in them. They appear only when they meet the same published criteria we apply to third-party funds, and nothing here is a recommendation for you.”
Medium if undisclosed, Low with the disclosure and the criteria in place. It goes wrong if we show our own fund without saying it is ours, or weight the surface toward it, so a prospect cannot tell house product from a neutral view.
- The CIO funds carry a standing line: these are JPC's own CIO strategies and we have an interest in them.
- The asset-management funds sit on an open shelf next to third-party managers; the same published criteria apply to ours and to theirs.
- Balanced presentation — no superlatives, no visual weighting toward our own.
- Our own products and third-party funds clearly labelled as such.
- Framed as conviction, never “buy this,” and never a personal recommendation, with an audit trail of what was shown and disclosed.
Honest about what is still open
What goes to Compliance with the prototype.
Surfaced, not smoothed over. Each is a firm-posture or cross-border question the rule text alone cannot settle.
Singapore
MAS does not codify a reverse-solicitation safe harbour — confirm the logged click is corroborating evidence, not the legal basis. And confirm the disclosure form for showing our own funds.
Owner · Compliance
Hong Kong
Confirm a documented adviser evidence-record discharges the Code 5.1A derivatives duty, and the exact conflicts-disclosure wording under the Code for our own products.
Owner · Compliance
United Kingdom
Cross-border reach of the financial-promotions regime to a UK-resident prospect on a non-UK booking centre, and the Art 6 basis and retention for prospect K&E.
Owner · Compliance + DPO
How this is evidenced
Every rule is cited to primary regulator text, confirmed on 2026-06-15, and the page was independently re-checked with a second model (Codex). Verbatim regulator wording sits in quotation marks; everything else is our summary. The conflict-of-interest rules for our own products are codified in the UK and reached by principle in Hong Kong and Singapore — the HK and SG specifics go to Compliance. Switzerland and the EU are out of scope here until re-verified.
The one-line answer
Take the light path where the rules allow it, show a flavour rather than advice, disclose where we have an interest, and show the disclosure before the prospect proceeds.