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Question 1 of 28
1. Question
After identifying an issue related to Calculating the financial impact of the loss of a key executive on business profits, what is the best next step? A Singapore-based private limited company is concerned about the sudden loss of its Lead Architect, whose specialized expertise is responsible for securing 40% of the firm’s annual contracts. The financial adviser needs to determine an appropriate sum assured for a Key Person Insurance policy.
Correct
Correct: In the Singapore financial advisory framework, particularly under the Financial Advisers Act (FAA) which requires a reasonable basis for recommendations, the best practice for quantifying key person loss is to use a combination of the ‘Contribution to Profit’ method and the ‘Replacement Cost’ method. This involves analyzing the specific portion of net profit attributable to the individual’s expertise and adding the tangible costs of finding, hiring, and training a replacement (including the ‘gestation period’ where the new hire is not yet fully productive).
Incorrect: Using a fixed salary multiplier is a rule of thumb that may not reflect the actual economic impact on a specific business, potentially leading to inadequate coverage. Focusing on credit facilities or loan amounts addresses debt protection rather than the loss of operational profit. Using the value of an equity stake is more relevant for buy-sell agreements and shareholder protection rather than quantifying the loss of the individual’s functional contribution to the company’s earnings.
Takeaway: A robust key person valuation must account for both the direct loss of business income and the specific costs associated with recruiting and developing a replacement to ensure a reasonable basis for the insurance recommendation.
Incorrect
Correct: In the Singapore financial advisory framework, particularly under the Financial Advisers Act (FAA) which requires a reasonable basis for recommendations, the best practice for quantifying key person loss is to use a combination of the ‘Contribution to Profit’ method and the ‘Replacement Cost’ method. This involves analyzing the specific portion of net profit attributable to the individual’s expertise and adding the tangible costs of finding, hiring, and training a replacement (including the ‘gestation period’ where the new hire is not yet fully productive).
Incorrect: Using a fixed salary multiplier is a rule of thumb that may not reflect the actual economic impact on a specific business, potentially leading to inadequate coverage. Focusing on credit facilities or loan amounts addresses debt protection rather than the loss of operational profit. Using the value of an equity stake is more relevant for buy-sell agreements and shareholder protection rather than quantifying the loss of the individual’s functional contribution to the company’s earnings.
Takeaway: A robust key person valuation must account for both the direct loss of business income and the specific costs associated with recruiting and developing a replacement to ensure a reasonable basis for the insurance recommendation.
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Question 2 of 28
2. Question
During a routine supervisory engagement with an audit firm in Singapore, the authority asks about Flexible benefit programs and their administration in Singapore SMEs in the context of risk appetite review. They observe that a medium-sized enterprise has recently transitioned from a fixed benefit structure to a flexible points-based system. The firm’s risk assessment identifies potential compliance gaps regarding the classification of benefits for tax reporting and statutory contributions. Which of the following considerations is most critical for the SME to ensure that the administration of this flexible benefit program remains compliant with Singapore’s regulatory and tax framework?
Correct
Correct: In Singapore, the distinction between a reimbursement (paying back an actual expense incurred) and an allowance (a fixed sum given regardless of expense) is vital. Under the Central Provident Fund (CPF) Act and Inland Revenue Authority of Singapore (IRAS) regulations, cash allowances are typically considered wages and are subject to CPF contributions and income tax. Proper administration requires SMEs to track these choices accurately to ensure correct statutory filings and avoid penalties for under-contribution or incorrect tax reporting.
Incorrect: The assumption that all flexible benefits are exempt from CPF is incorrect because the CPF Board determines liability based on whether the payment is a wage or a reimbursement, not the total amount. Converting statutory minimum requirements like sick leave into flexible points is a violation of the Employment Act, which mandates these as non-negotiable rights. Simply keeping receipts does not automatically make a benefit non-taxable; the taxability is determined by the nature of the benefit according to IRAS rules, regardless of the record-keeping system.
Takeaway: Effective administration of flexible benefits in Singapore requires precise classification of choices to meet CPF and IRAS compliance requirements regarding wages and reimbursements.
Incorrect
Correct: In Singapore, the distinction between a reimbursement (paying back an actual expense incurred) and an allowance (a fixed sum given regardless of expense) is vital. Under the Central Provident Fund (CPF) Act and Inland Revenue Authority of Singapore (IRAS) regulations, cash allowances are typically considered wages and are subject to CPF contributions and income tax. Proper administration requires SMEs to track these choices accurately to ensure correct statutory filings and avoid penalties for under-contribution or incorrect tax reporting.
Incorrect: The assumption that all flexible benefits are exempt from CPF is incorrect because the CPF Board determines liability based on whether the payment is a wage or a reimbursement, not the total amount. Converting statutory minimum requirements like sick leave into flexible points is a violation of the Employment Act, which mandates these as non-negotiable rights. Simply keeping receipts does not automatically make a benefit non-taxable; the taxability is determined by the nature of the benefit according to IRAS rules, regardless of the record-keeping system.
Takeaway: Effective administration of flexible benefits in Singapore requires precise classification of choices to meet CPF and IRAS compliance requirements regarding wages and reimbursements.
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Question 3 of 28
3. Question
Excerpt from a customer complaint: In work related to Corporate Social Responsibility (CSR) and its relevance to Singapore businesses as part of transaction monitoring at a listed company in Singapore, it was noted that the board of directors is currently evaluating the integration of environmental, social, and governance (ESG) factors into their annual reporting cycle. A group of institutional investors has raised concerns that the current CSR initiatives lack alignment with the SGX-ST Listing Rules regarding sustainability reporting. Which of the following best describes the regulatory requirements and expectations for a Singapore-listed company regarding CSR and sustainability disclosures?
Correct
Correct: Under the SGX-ST Listing Rules, all listed issuers in Singapore are required to prepare an annual sustainability report. This report must be issued on a comply or explain basis and must include several primary components: material ESG factors, climate-related disclosures (which are being phased in as mandatory for certain sectors), policies, practices, and performance, targets, a sustainability reporting framework, and a board statement. Additionally, listed companies must disclose their board diversity policy, including targets and timelines.
Incorrect: The requirement for sustainability reporting is not based on a specific 5 percent profit threshold but rather on the materiality of ESG factors to the business and its stakeholders. While the Monetary Authority of Singapore (MAS) and ACRA are key regulators, they do not mandate CSR audits for all private limited companies; the specific sustainability reporting requirements discussed here apply to listed issuers under SGX rules. Sustainability reporting is not voluntary for listed companies; it is a mandatory requirement under the Listing Rules, even if the company has a high corporate governance score.
Takeaway: Singapore-listed companies must comply with SGX-ST Listing Rules by publishing annual sustainability reports that cover material ESG factors and climate disclosures on a comply-or-explain basis.
Incorrect
Correct: Under the SGX-ST Listing Rules, all listed issuers in Singapore are required to prepare an annual sustainability report. This report must be issued on a comply or explain basis and must include several primary components: material ESG factors, climate-related disclosures (which are being phased in as mandatory for certain sectors), policies, practices, and performance, targets, a sustainability reporting framework, and a board statement. Additionally, listed companies must disclose their board diversity policy, including targets and timelines.
Incorrect: The requirement for sustainability reporting is not based on a specific 5 percent profit threshold but rather on the materiality of ESG factors to the business and its stakeholders. While the Monetary Authority of Singapore (MAS) and ACRA are key regulators, they do not mandate CSR audits for all private limited companies; the specific sustainability reporting requirements discussed here apply to listed issuers under SGX rules. Sustainability reporting is not voluntary for listed companies; it is a mandatory requirement under the Listing Rules, even if the company has a high corporate governance score.
Takeaway: Singapore-listed companies must comply with SGX-ST Listing Rules by publishing annual sustainability reports that cover material ESG factors and climate disclosures on a comply-or-explain basis.
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Question 4 of 28
4. Question
You are Kenji Garcia, the risk manager at an audit firm in Singapore. While working on The use of a Trustee to hold insurance policies for succession funding during gifts and entertainment, you receive an incident report. The issue is that a client, a director of a Singapore-based private limited company, is concerned about the legal implications of their current cross-purchase buy-sell arrangement. The report indicates that the directors are worried that if one of them passes away, the insurance proceeds intended for the share buyout might be subject to claims by the surviving director’s personal creditors or delayed by the probate process. They are considering appointing an independent trustee to hold the policies instead.
Correct
Correct: In Singapore, using an independent trustee to hold insurance policies for business succession planning provides significant legal advantages. It ensures that the policy proceeds are held in trust for the specific purpose of the buy-sell agreement, thereby ‘ring-fencing’ the money from the personal creditors of the surviving shareholders. Furthermore, because the trustee is the legal owner of the policy, the death benefit can be paid out and utilized immediately according to the trust deed, bypassing the often lengthy probate process required for the deceased’s personal estate.
Incorrect: The suggestion that premiums become tax-deductible simply by using a trustee is incorrect; premiums for succession funding (capital nature) are generally not deductible for the company or individuals. There is no MAS requirement under the Securities and Futures Act that mandates a trustee for buy-sell agreements based on the number of shareholders. Finally, the transfer of shares in a private limited company is generally not subject to GST, and a trustee structure is not used for the purpose of GST exemption in this context.
Takeaway: Utilizing a trustee in business succession funding provides essential creditor protection and ensures immediate liquidity for share buyouts by avoiding the probate process.
Incorrect
Correct: In Singapore, using an independent trustee to hold insurance policies for business succession planning provides significant legal advantages. It ensures that the policy proceeds are held in trust for the specific purpose of the buy-sell agreement, thereby ‘ring-fencing’ the money from the personal creditors of the surviving shareholders. Furthermore, because the trustee is the legal owner of the policy, the death benefit can be paid out and utilized immediately according to the trust deed, bypassing the often lengthy probate process required for the deceased’s personal estate.
Incorrect: The suggestion that premiums become tax-deductible simply by using a trustee is incorrect; premiums for succession funding (capital nature) are generally not deductible for the company or individuals. There is no MAS requirement under the Securities and Futures Act that mandates a trustee for buy-sell agreements based on the number of shareholders. Finally, the transfer of shares in a private limited company is generally not subject to GST, and a trustee structure is not used for the purpose of GST exemption in this context.
Takeaway: Utilizing a trustee in business succession funding provides essential creditor protection and ensures immediate liquidity for share buyouts by avoiding the probate process.
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Question 5 of 28
5. Question
Excerpt from a suspicious activity escalation: In work related to Differences between a General Partnership and a Limited Liability Partnership (LLP) in Singapore as part of control testing at a private bank in Singapore, it was noted that a group of three specialist doctors are seeking credit facilities for their new clinic. They are currently debating whether to register as a General Partnership or a Limited Liability Partnership (LLP) under the Accounting and Corporate Regulatory Authority (ACRA). Which of the following best describes a fundamental legal distinction between these two structures regarding the liability of the partners in Singapore?
Correct
Correct: Under the Limited Liability Partnerships Act in Singapore, an LLP is a body corporate and has a legal personality separate from that of its partners. This protects partners from being personally liable for the debts of the LLP. In contrast, a General Partnership governed by the Partnership Act does not have a separate legal personality, and partners face unlimited personal liability for the firm’s debts and obligations incurred while they are partners.
Incorrect: The suggestion that General Partnerships have limited liability based on capital contribution is incorrect as they involve unlimited liability. The claim that an LLP requires an unlimited liability partner is a confusion with a Limited Partnership (LP), which is a different structure from an LLP. Furthermore, partners in an LLP are never immune from personal liability for their own wrongful acts or professional negligence, even if the entity itself provides a shield against the firm’s general commercial debts.
Takeaway: The key distinction is that an LLP is a separate legal entity providing limited liability protection for the firm’s debts, whereas a General Partnership is not a separate entity and carries unlimited personal liability for all partners.
Incorrect
Correct: Under the Limited Liability Partnerships Act in Singapore, an LLP is a body corporate and has a legal personality separate from that of its partners. This protects partners from being personally liable for the debts of the LLP. In contrast, a General Partnership governed by the Partnership Act does not have a separate legal personality, and partners face unlimited personal liability for the firm’s debts and obligations incurred while they are partners.
Incorrect: The suggestion that General Partnerships have limited liability based on capital contribution is incorrect as they involve unlimited liability. The claim that an LLP requires an unlimited liability partner is a confusion with a Limited Partnership (LP), which is a different structure from an LLP. Furthermore, partners in an LLP are never immune from personal liability for their own wrongful acts or professional negligence, even if the entity itself provides a shield against the firm’s general commercial debts.
Takeaway: The key distinction is that an LLP is a separate legal entity providing limited liability protection for the firm’s debts, whereas a General Partnership is not a separate entity and carries unlimited personal liability for all partners.
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Question 6 of 28
6. Question
After identifying an issue related to Valuing intellectual property under the Intellectual Property Office of Singapore (IPOS), what is the best next step for a Singapore-based technology firm looking to use its patented software as collateral for a business expansion loan?
Correct
Correct: In the context of Singapore’s financial landscape, the Income Approach is the most appropriate method for valuing intellectual property for commercial purposes such as financing. This method focuses on the future economic benefits the IP is expected to generate, which is what lenders and investors prioritize. Engaging an independent, qualified valuer ensures that the assessment meets the professional standards expected by Singapore financial institutions and aligns with IPOS guidelines for IP management.
Incorrect: The Cost Approach is often considered inadequate for IP valuation because the historical cost of development rarely correlates with the asset’s actual economic value or income-generating potential. The Market Approach is difficult to apply to IP because these assets are unique; using unadjusted prices from other transactions ignores the specific legal protections and market variables unique to the firm’s IP. The net book value under Singapore Financial Reporting Standards (SFRS) is an accounting measure based on historical cost less amortization, which does not reflect the current fair market value or the future earning capacity of the intellectual property.
Takeaway: Professional IP valuation in Singapore should prioritize the Income Approach to accurately reflect the asset’s future earning potential for commercial and financing purposes.
Incorrect
Correct: In the context of Singapore’s financial landscape, the Income Approach is the most appropriate method for valuing intellectual property for commercial purposes such as financing. This method focuses on the future economic benefits the IP is expected to generate, which is what lenders and investors prioritize. Engaging an independent, qualified valuer ensures that the assessment meets the professional standards expected by Singapore financial institutions and aligns with IPOS guidelines for IP management.
Incorrect: The Cost Approach is often considered inadequate for IP valuation because the historical cost of development rarely correlates with the asset’s actual economic value or income-generating potential. The Market Approach is difficult to apply to IP because these assets are unique; using unadjusted prices from other transactions ignores the specific legal protections and market variables unique to the firm’s IP. The net book value under Singapore Financial Reporting Standards (SFRS) is an accounting measure based on historical cost less amortization, which does not reflect the current fair market value or the future earning capacity of the intellectual property.
Takeaway: Professional IP valuation in Singapore should prioritize the Income Approach to accurately reflect the asset’s future earning potential for commercial and financing purposes.
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Question 7 of 28
7. Question
An incident ticket at a fund administrator in Singapore is raised about Transparency and disclosure requirements for private companies during record-keeping. The report states that a private limited company client recently underwent a restructuring where a new individual acquired a 30% stake in the voting rights. The compliance team is reviewing the timeline for updating the Register of Registrable Controllers (RORC) to ensure adherence to the Accounting and Corporate Regulatory Authority (ACRA) requirements. Given that the company has already identified and confirmed the particulars of this new controller, what is the mandatory timeframe for the company to update its internal RORC and subsequently lodge the information with ACRA?
Correct
Correct: In Singapore, under the Companies Act, companies (unless exempted) are required to maintain a Register of Registrable Controllers (RORC). When a company has confirmed the particulars of a registrable controller, it must update its internal register within 2 business days. Following the update of the internal register, the company must then lodge the same information with ACRA’s central RORC database within 2 business days. This ensures that the regulatory authorities have timely and accurate data regarding the beneficial ownership and control of corporate entities.
Incorrect: Updating the register only during the Annual Return filing is incorrect as the law requires immediate updates to maintain transparency. The suggestion that lodging with ACRA is only for foreign entities is false; all registrable controllers must be reported regardless of nationality. Furthermore, the RORC is not a public document and should not be made available for public inspection; it is intended for use by ACRA and law enforcement agencies to combat money laundering and financial crimes.
Takeaway: Singapore private companies must update their internal Register of Registrable Controllers within 2 business days of confirmation and lodge that data with ACRA within a further 2 business days.
Incorrect
Correct: In Singapore, under the Companies Act, companies (unless exempted) are required to maintain a Register of Registrable Controllers (RORC). When a company has confirmed the particulars of a registrable controller, it must update its internal register within 2 business days. Following the update of the internal register, the company must then lodge the same information with ACRA’s central RORC database within 2 business days. This ensures that the regulatory authorities have timely and accurate data regarding the beneficial ownership and control of corporate entities.
Incorrect: Updating the register only during the Annual Return filing is incorrect as the law requires immediate updates to maintain transparency. The suggestion that lodging with ACRA is only for foreign entities is false; all registrable controllers must be reported regardless of nationality. Furthermore, the RORC is not a public document and should not be made available for public inspection; it is intended for use by ACRA and law enforcement agencies to combat money laundering and financial crimes.
Takeaway: Singapore private companies must update their internal Register of Registrable Controllers within 2 business days of confirmation and lodge that data with ACRA within a further 2 business days.
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Question 8 of 28
8. Question
A monitoring dashboard for a private bank in Singapore shows an unusual pattern linked to Business interruption insurance and its role in disaster recovery during outsourcing. The key detail is that a corporate client, a specialized medical group, has experienced a total cessation of operations for 72 hours due to a ransomware attack on their outsourced cloud service provider. The client’s current Business Interruption policy only covers losses resulting from physical damage to their own premises. In the context of risk assessment and disaster recovery planning for Singapore-based business owners, which strategy would best address this specific vulnerability?
Correct
Correct: Contingent Business Interruption (CBI) coverage, also known as dependency business interruption, is essential for businesses that rely on third-party providers. Standard Business Interruption (BI) policies in Singapore typically require physical damage to the insured’s own property to trigger a claim. CBI extends this protection to include losses resulting from disruptions at the premises of a supplier or service provider, such as a cloud host. Given the Monetary Authority of Singapore (MAS) emphasis on outsourcing risk management, ensuring financial recovery through appropriate insurance extensions is a critical part of a robust risk assessment.
Incorrect: Public Liability insurance is designed to cover legal liability for third-party bodily injury or property damage, not the insured’s own loss of revenue. Fire and Extraneous Perils policies generally require physical damage (like fire or flood) to the insured’s assets and do not cover pure economic loss from cyber events or third-party outages. While a Business Continuity Plan (BCP) is a vital procedural requirement under Singapore’s BCM guidelines, a plan focused only on internal backups fails to provide the necessary financial liquidity to replace lost income during a prolonged external service outage.
Takeaway: Business owners must ensure their Business Interruption insurance includes contingent coverage for third-party service providers to mitigate financial losses from external supply chain or IT disruptions.
Incorrect
Correct: Contingent Business Interruption (CBI) coverage, also known as dependency business interruption, is essential for businesses that rely on third-party providers. Standard Business Interruption (BI) policies in Singapore typically require physical damage to the insured’s own property to trigger a claim. CBI extends this protection to include losses resulting from disruptions at the premises of a supplier or service provider, such as a cloud host. Given the Monetary Authority of Singapore (MAS) emphasis on outsourcing risk management, ensuring financial recovery through appropriate insurance extensions is a critical part of a robust risk assessment.
Incorrect: Public Liability insurance is designed to cover legal liability for third-party bodily injury or property damage, not the insured’s own loss of revenue. Fire and Extraneous Perils policies generally require physical damage (like fire or flood) to the insured’s assets and do not cover pure economic loss from cyber events or third-party outages. While a Business Continuity Plan (BCP) is a vital procedural requirement under Singapore’s BCM guidelines, a plan focused only on internal backups fails to provide the necessary financial liquidity to replace lost income during a prolonged external service outage.
Takeaway: Business owners must ensure their Business Interruption insurance includes contingent coverage for third-party service providers to mitigate financial losses from external supply chain or IT disruptions.
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Question 9 of 28
9. Question
During a routine supervisory engagement with a broker-dealer in Singapore, the authority asks about Productivity and Innovation Credit (PIC) legacy issues and current digitalization grants in the context of conflicts of interest. They observe that several business owner clients were recently advised to upgrade their financial reporting systems using the Productivity Solutions Grant (PSG) through a specific pre-approved vendor who is also a major corporate client of the firm. The firm did not maintain a record of why this specific vendor was recommended over other pre-approved alternatives. From a risk assessment perspective, what is the most significant regulatory concern regarding this arrangement?
Correct
Correct: Under the Financial Advisers Act (FAA) and the MAS Guidelines on Business Conduct, financial advisers must disclose any conflict of interest that could reasonably be expected to influence their recommendation. Recommending a vendor that is also a corporate client of the firm without disclosure or a clear, objective selection rationale undermines the requirement to provide objective advice and act in the client’s best interest. This is particularly sensitive when helping clients navigate government-funded schemes like the Productivity Solutions Grant (PSG).
Incorrect: While IRAS and Enterprise Singapore (ESG) have strict rules for grants, an existing corporate relationship between a vendor and a consultant does not automatically invalidate a grant, provided the vendor is pre-approved and the transaction is at arm’s length. Market misconduct under the SFA typically refers to activities like wash sales or insider trading, which are not the primary issues here. PDPA concerns arise during the actual transfer of data, but the core regulatory failure in this scenario is the conflict of interest and lack of transparency in the advisory process.
Takeaway: Financial advisers must identify and disclose all potential conflicts of interest when recommending third-party vendors for government-funded digitalization grants to ensure the integrity of the advice.
Incorrect
Correct: Under the Financial Advisers Act (FAA) and the MAS Guidelines on Business Conduct, financial advisers must disclose any conflict of interest that could reasonably be expected to influence their recommendation. Recommending a vendor that is also a corporate client of the firm without disclosure or a clear, objective selection rationale undermines the requirement to provide objective advice and act in the client’s best interest. This is particularly sensitive when helping clients navigate government-funded schemes like the Productivity Solutions Grant (PSG).
Incorrect: While IRAS and Enterprise Singapore (ESG) have strict rules for grants, an existing corporate relationship between a vendor and a consultant does not automatically invalidate a grant, provided the vendor is pre-approved and the transaction is at arm’s length. Market misconduct under the SFA typically refers to activities like wash sales or insider trading, which are not the primary issues here. PDPA concerns arise during the actual transfer of data, but the core regulatory failure in this scenario is the conflict of interest and lack of transparency in the advisory process.
Takeaway: Financial advisers must identify and disclose all potential conflicts of interest when recommending third-party vendors for government-funded digitalization grants to ensure the integrity of the advice.
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Question 10 of 28
10. Question
Excerpt from an incident report: In work related to The role of the Representative Notification Framework (RNF) for financial advisers as part of transaction monitoring at a mid-sized retail bank in Singapore, it was noted that a newly recruited relationship manager intended to begin soliciting investment products to business owners immediately after signing the employment contract. The compliance department intervened to ensure adherence to the Financial Advisers Act (FAA) regarding the appointment of representatives. Which of the following best describes the requirement for the bank under the RNF before the individual can perform regulated activities?
Correct
Correct: Under the Representative Notification Framework (RNF) in Singapore, a principal (such as a bank) must notify the Monetary Authority of Singapore (MAS) of its intention to appoint a representative to conduct regulated activities under the Financial Advisers Act (FAA). The individual can only commence these activities once their name and representative number are reflected on the public Register of Representatives maintained by MAS. The principal bears the primary responsibility for ensuring the individual meets the Fit and Proper criteria before submission.
Incorrect: Allowing a representative to provide advice before their name appears on the public register is a breach of the FAA, as notification must precede the commencement of regulated activities. The RNF is an electronic notification system, and MAS no longer issues physical licenses to individual representatives. The RNF is managed by MAS, not the SGX, and it applies to all individuals providing financial advisory services under the FAA, regardless of whether the clients are retail or business owners.
Takeaway: A representative must be formally notified to MAS and appear on the public Register of Representatives before they can legally perform regulated financial advisory services in Singapore.
Incorrect
Correct: Under the Representative Notification Framework (RNF) in Singapore, a principal (such as a bank) must notify the Monetary Authority of Singapore (MAS) of its intention to appoint a representative to conduct regulated activities under the Financial Advisers Act (FAA). The individual can only commence these activities once their name and representative number are reflected on the public Register of Representatives maintained by MAS. The principal bears the primary responsibility for ensuring the individual meets the Fit and Proper criteria before submission.
Incorrect: Allowing a representative to provide advice before their name appears on the public register is a breach of the FAA, as notification must precede the commencement of regulated activities. The RNF is an electronic notification system, and MAS no longer issues physical licenses to individual representatives. The RNF is managed by MAS, not the SGX, and it applies to all individuals providing financial advisory services under the FAA, regardless of whether the clients are retail or business owners.
Takeaway: A representative must be formally notified to MAS and appear on the public Register of Representatives before they can legally perform regulated financial advisory services in Singapore.
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Question 11 of 28
11. Question
Your team is drafting a policy on Intestacy laws in Singapore and their impact on business ownership as part of periodic review for a payment services provider in Singapore. A key unresolved point is how the Intestate Succession Act (ISA) affects the continuity of a private limited company when a majority shareholder dies without a Will. Consider a scenario where a founder holds 70% of the shares, is survived by a spouse and two minor children, and no Shareholders’ Agreement is in place. What is the legal distribution of these shares and the associated risk to the business?
Correct
Correct: Under Section 7, Rule 2 of the Intestate Succession Act of Singapore, if a person dies intestate leaving a spouse and children, the surviving spouse is entitled to half of the estate, and the children are entitled to the other half in equal shares. In a business context, this fragments the majority stake. Furthermore, because the children are minors, they cannot hold legal title to the shares directly; their interest must be held in trust. This creates significant risk because the trustees (usually the surviving spouse and another administrator) must act in the best interests of the minors, which may not align with the commercial needs of the business, potentially leading to deadlocks in shareholder resolutions.
Incorrect: The claim that the spouse inherits 100% is incorrect because under the ISA, the spouse only receives the entire estate if there are no children or descendants. The idea that shares automatically convert to non-voting shares is not a provision of the Singapore Companies Act; share rights are determined by the Company’s Constitution and any existing Shareholders’ Agreement. There is no legal requirement in Singapore law that mandates the automatic liquidation of private company shares within 6 months for intestate estates; the administrator has the power to manage the assets, but liquidation is not a statutory requirement unless necessary to pay debts or if specified in the company’s own articles.
Takeaway: In Singapore, the Intestate Succession Act distributes assets between a spouse and children in a 50/50 split, which can cause business paralysis and unintended governance challenges when minor children are involved.
Incorrect
Correct: Under Section 7, Rule 2 of the Intestate Succession Act of Singapore, if a person dies intestate leaving a spouse and children, the surviving spouse is entitled to half of the estate, and the children are entitled to the other half in equal shares. In a business context, this fragments the majority stake. Furthermore, because the children are minors, they cannot hold legal title to the shares directly; their interest must be held in trust. This creates significant risk because the trustees (usually the surviving spouse and another administrator) must act in the best interests of the minors, which may not align with the commercial needs of the business, potentially leading to deadlocks in shareholder resolutions.
Incorrect: The claim that the spouse inherits 100% is incorrect because under the ISA, the spouse only receives the entire estate if there are no children or descendants. The idea that shares automatically convert to non-voting shares is not a provision of the Singapore Companies Act; share rights are determined by the Company’s Constitution and any existing Shareholders’ Agreement. There is no legal requirement in Singapore law that mandates the automatic liquidation of private company shares within 6 months for intestate estates; the administrator has the power to manage the assets, but liquidation is not a statutory requirement unless necessary to pay debts or if specified in the company’s own articles.
Takeaway: In Singapore, the Intestate Succession Act distributes assets between a spouse and children in a 50/50 split, which can cause business paralysis and unintended governance challenges when minor children are involved.
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Question 12 of 28
12. Question
Your team is drafting a policy on The concept of lifting the corporate veil in Singapore judicial precedents as part of onboarding for an audit firm in Singapore. A key unresolved point is how to advise clients on the specific judicial grounds for piercing the corporate veil when a business owner operates multiple private limited companies. In a scenario where a director uses a newly incorporated entity specifically to circumvent a non-compete injunction issued against his primary firm, which principle would the Singapore courts most likely apply to lift the corporate veil?
Correct
Correct: In Singapore, judicial precedent (following cases like Tjong Very Sumito v Antig Investments Pte Ltd) establishes that the corporate veil may be lifted if the corporate form is used as a ‘facade’ or ‘sham’. This occurs when the company is interposed to avoid a pre-existing legal obligation or to deliberately evade the law. In the scenario described, using a new company to bypass a non-compete injunction is a classic example of using the corporate form to frustrate legal obligations, justifying the court’s intervention to look behind the veil.
Incorrect: Exercising absolute control or being a sole shareholder is insufficient on its own to lift the veil, as the principle of separate legal personality from Salomon v Salomon remains the baseline in Singapore law. Failure to meet ACRA’s administrative or capital requirements is a regulatory compliance issue but does not constitute a judicial ground for lifting the veil. The ‘Single Economic Unit’ theory is generally rejected in Singapore as a standalone ground for lifting the veil, as courts respect the separate legal identity of each company within a group unless a facade or agency relationship is proven.
Takeaway: Singapore courts will only lift the corporate veil in limited circumstances, primarily when the corporate structure is used as a facade to evade existing legal duties or perpetrate fraud.
Incorrect
Correct: In Singapore, judicial precedent (following cases like Tjong Very Sumito v Antig Investments Pte Ltd) establishes that the corporate veil may be lifted if the corporate form is used as a ‘facade’ or ‘sham’. This occurs when the company is interposed to avoid a pre-existing legal obligation or to deliberately evade the law. In the scenario described, using a new company to bypass a non-compete injunction is a classic example of using the corporate form to frustrate legal obligations, justifying the court’s intervention to look behind the veil.
Incorrect: Exercising absolute control or being a sole shareholder is insufficient on its own to lift the veil, as the principle of separate legal personality from Salomon v Salomon remains the baseline in Singapore law. Failure to meet ACRA’s administrative or capital requirements is a regulatory compliance issue but does not constitute a judicial ground for lifting the veil. The ‘Single Economic Unit’ theory is generally rejected in Singapore as a standalone ground for lifting the veil, as courts respect the separate legal identity of each company within a group unless a facade or agency relationship is proven.
Takeaway: Singapore courts will only lift the corporate veil in limited circumstances, primarily when the corporate structure is used as a facade to evade existing legal duties or perpetrate fraud.
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Question 13 of 28
13. Question
An incident ticket at a private bank in Singapore is raised about Professional ethics and the code of conduct for ChFC holders in Singapore during business continuity. The report states that during a 48-hour core banking system failure, a ChFC holder was pressured by a long-term business owner client to manually facilitate a complex currency hedge for a 5 million SGD exposure without the standard automated suitability assessment. The ChFC holder must decide how to uphold the principles of Integrity and Professionalism while the bank operates under its Business Continuity Plan (BCP). Which action best demonstrates adherence to the ChFC Code of Ethics in this situation?
Correct
Correct: According to the ChFC Code of Ethics and the standards expected by the Singapore College of Insurance (SCI), a ChFC holder must act with Integrity, Professionalism, and Objectivity at all times. Even during a business continuity event or system failure, the duty to provide competent advice and full disclosure of material risks remains. Manually documenting the suitability and ensuring the client is fully informed before execution fulfills the ethical obligation to place the client’s interest first while maintaining professional standards.
Incorrect: Postponing disclosures or suitability assessments (as in the second option) is a violation of the principle of Fairness and the duty to inform the client of risks before they commit to a transaction. Seeking an exemption from ethical codes (as in the third option) is not possible as ethical principles are fundamental and not subject to system-related waivers. Simply avoiding the trade to protect oneself from liability (as in the fourth option) may fail the principle of Diligence and the duty to act in the client’s best interest if the delay causes foreseeable harm that could have been mitigated through proper manual procedures.
Takeaway: Ethical obligations, including risk disclosure and suitability, remain mandatory for ChFC holders in Singapore even during technical disruptions or business continuity scenarios.
Incorrect
Correct: According to the ChFC Code of Ethics and the standards expected by the Singapore College of Insurance (SCI), a ChFC holder must act with Integrity, Professionalism, and Objectivity at all times. Even during a business continuity event or system failure, the duty to provide competent advice and full disclosure of material risks remains. Manually documenting the suitability and ensuring the client is fully informed before execution fulfills the ethical obligation to place the client’s interest first while maintaining professional standards.
Incorrect: Postponing disclosures or suitability assessments (as in the second option) is a violation of the principle of Fairness and the duty to inform the client of risks before they commit to a transaction. Seeking an exemption from ethical codes (as in the third option) is not possible as ethical principles are fundamental and not subject to system-related waivers. Simply avoiding the trade to protect oneself from liability (as in the fourth option) may fail the principle of Diligence and the duty to act in the client’s best interest if the delay causes foreseeable harm that could have been mitigated through proper manual procedures.
Takeaway: Ethical obligations, including risk disclosure and suitability, remain mandatory for ChFC holders in Singapore even during technical disruptions or business continuity scenarios.
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Question 14 of 28
14. Question
A monitoring dashboard for a credit union in Singapore shows an unusual pattern linked to Cross-purchase funding methods for shareholder succession in private limited companies during periodic review. The key detail is that three shareholders of a Singapore-based engineering firm are evaluating their Buy-Sell Agreement. They are concerned about the long-term tax implications and the cost basis of their holdings should one of them pass away. Under a cross-purchase arrangement funded by life insurance policies, which of the following is a significant characteristic regarding the surviving shareholders’ position?
Correct
Correct: In a cross-purchase arrangement, the surviving shareholders personally purchase the shares of the deceased shareholder using the insurance proceeds. This results in a ‘step-up’ in the cost basis of their total shares, which is the price paid for the new shares. This is a distinct advantage over an entity-purchase (redemption) arrangement where the company buys back the shares and the surviving shareholders’ basis remains unchanged despite their increased percentage of ownership.
Incorrect: Option b is incorrect because premiums paid for personal life insurance in a cross-purchase setup are generally not tax-deductible for the individuals or the business. Option c is incorrect because cross-purchase arrangements actually increase in complexity as the number of shareholders grows, requiring n(n-1) policies (e.g., 3 shareholders require 6 policies). Option d is incorrect because life insurance proceeds received by individuals in Singapore are generally treated as capital receipts and are not subject to income tax.
Takeaway: A cross-purchase funding method allows surviving shareholders to increase their cost basis in the company, which is a key structural benefit compared to entity-redemption methods.
Incorrect
Correct: In a cross-purchase arrangement, the surviving shareholders personally purchase the shares of the deceased shareholder using the insurance proceeds. This results in a ‘step-up’ in the cost basis of their total shares, which is the price paid for the new shares. This is a distinct advantage over an entity-purchase (redemption) arrangement where the company buys back the shares and the surviving shareholders’ basis remains unchanged despite their increased percentage of ownership.
Incorrect: Option b is incorrect because premiums paid for personal life insurance in a cross-purchase setup are generally not tax-deductible for the individuals or the business. Option c is incorrect because cross-purchase arrangements actually increase in complexity as the number of shareholders grows, requiring n(n-1) policies (e.g., 3 shareholders require 6 policies). Option d is incorrect because life insurance proceeds received by individuals in Singapore are generally treated as capital receipts and are not subject to income tax.
Takeaway: A cross-purchase funding method allows surviving shareholders to increase their cost basis in the company, which is a key structural benefit compared to entity-redemption methods.
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Question 15 of 28
15. Question
Your team is drafting a policy on The use of Wills to bequeath shares in a Singapore private company as part of regulatory inspection for a mid-sized retail bank in Singapore. A key unresolved point is how to address the potential conflict between a testator’s specific bequest in a Will and the restrictive covenants found in a company’s Constitution. A client, who is a majority shareholder in a private limited company, intends to leave his shares to his daughter, but the company’s Constitution requires all share transfers to be approved by the Board of Directors. In the context of Singapore law, what is the primary legal consideration when a Will purports to transfer shares in a private company that has restrictive transfer provisions in its Constitution?
Correct
Correct: In Singapore, the Constitution of a private company (formerly the Memorandum and Articles of Association) constitutes a binding contract between the company and its members. If the Constitution contains restrictions on the transfer of shares, such as a requirement for Board approval or rights of first refusal for existing shareholders, these provisions are generally enforceable even against a beneficiary named in a Will. While the Will effectively transfers the ‘beneficial interest’ in the shares, the ‘legal title’ and the right to be registered in the Electronic Register of Members (ERM) maintained by ACRA are subject to the company’s internal governance rules.
Incorrect: The suggestion that a Will overrides the Constitution is incorrect because the Companies Act respects the contractual nature of a company’s internal regulations regarding share transfers. The claim that an executor has an absolute right to be registered as a member is false; while an executor has the right to deal with the shares (transmission), they do not automatically become a member with voting rights unless the Constitution permits it or the Board approves the registration. The idea that the Wills Act voids company restrictions is a misconception, as the Wills Act governs the formal validity of the Will itself, not the underlying property rights or corporate restrictions affecting the assets being bequeathed.
Takeaway: A bequest of shares in a Singapore private company is subject to the transfer restrictions and board discretion stipulated in the company’s Constitution.
Incorrect
Correct: In Singapore, the Constitution of a private company (formerly the Memorandum and Articles of Association) constitutes a binding contract between the company and its members. If the Constitution contains restrictions on the transfer of shares, such as a requirement for Board approval or rights of first refusal for existing shareholders, these provisions are generally enforceable even against a beneficiary named in a Will. While the Will effectively transfers the ‘beneficial interest’ in the shares, the ‘legal title’ and the right to be registered in the Electronic Register of Members (ERM) maintained by ACRA are subject to the company’s internal governance rules.
Incorrect: The suggestion that a Will overrides the Constitution is incorrect because the Companies Act respects the contractual nature of a company’s internal regulations regarding share transfers. The claim that an executor has an absolute right to be registered as a member is false; while an executor has the right to deal with the shares (transmission), they do not automatically become a member with voting rights unless the Constitution permits it or the Board approves the registration. The idea that the Wills Act voids company restrictions is a misconception, as the Wills Act governs the formal validity of the Will itself, not the underlying property rights or corporate restrictions affecting the assets being bequeathed.
Takeaway: A bequest of shares in a Singapore private company is subject to the transfer restrictions and board discretion stipulated in the company’s Constitution.
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Question 16 of 28
16. Question
Which approach is most appropriate when applying Capital allowances for plant and machinery under the Income Tax Act in a real-world setting? A Singapore-incorporated company has recently invested in a suite of new laptops for its consultants and a specialized heavy-duty conveyor system for its warehouse operations to improve productivity.
Correct
Correct: In Singapore, Section 19A of the Income Tax Act allows for accelerated capital allowances. Specifically, Section 19A(2) permits a 100% write-off for computers and prescribed automation equipment in one year. For other plant and machinery, such as the conveyor system, Section 19A(1) allows the company to elect for a three-year accelerated write-off (33.33% per year) instead of the standard working life method under Section 19. This approach optimizes the company’s tax position and cash flow.
Incorrect: Accounting depreciation is a non-deductible expense for tax purposes in Singapore and must be added back in the tax computation; capital allowances are calculated based on statutory rates instead. The ‘setting’ test is used to distinguish between the apparatus used for the business (plant) and the place where the business is conducted (setting); if an item is deemed ‘setting’, it generally fails to qualify as plant and machinery. The low-value asset provision allows a 100% write-off for assets costing up to $5,000 each, but the total claim for all such assets is capped at $30,000 per Year of Assessment, not $5,000.
Takeaway: Singapore tax law provides accelerated capital allowance options under Section 19A, including immediate write-offs for computers and three-year write-offs for general plant and machinery to encourage business investment.
Incorrect
Correct: In Singapore, Section 19A of the Income Tax Act allows for accelerated capital allowances. Specifically, Section 19A(2) permits a 100% write-off for computers and prescribed automation equipment in one year. For other plant and machinery, such as the conveyor system, Section 19A(1) allows the company to elect for a three-year accelerated write-off (33.33% per year) instead of the standard working life method under Section 19. This approach optimizes the company’s tax position and cash flow.
Incorrect: Accounting depreciation is a non-deductible expense for tax purposes in Singapore and must be added back in the tax computation; capital allowances are calculated based on statutory rates instead. The ‘setting’ test is used to distinguish between the apparatus used for the business (plant) and the place where the business is conducted (setting); if an item is deemed ‘setting’, it generally fails to qualify as plant and machinery. The low-value asset provision allows a 100% write-off for assets costing up to $5,000 each, but the total claim for all such assets is capped at $30,000 per Year of Assessment, not $5,000.
Takeaway: Singapore tax law provides accelerated capital allowance options under Section 19A, including immediate write-offs for computers and three-year write-offs for general plant and machinery to encourage business investment.
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Question 17 of 28
17. Question
Your team is drafting a policy on The importance of the Code of Ethics for financial planners in Singapore as part of client suitability for a listed company in Singapore. A key unresolved point is how to handle a situation where a financial planner, while conducting a 14-day suitability review for a business owner, discovers that the most appropriate insurance structure for the client’s buy-sell agreement offers significantly lower commission than a standard corporate policy favored by the firm’s current sales campaign. According to the ethical standards expected under the Financial Advisers Act (FAA) and MAS guidelines, what is the most appropriate course of action?
Correct
Correct: In Singapore, the Code of Ethics and the MAS Fair Dealing Guidelines require financial advisers to place the interests of their clients as their first priority. When a conflict arises between a firm’s commercial interests (such as sales targets or commissions) and the client’s specific needs (such as a buy-sell agreement structure), the adviser must provide objective advice and disclose the conflict to ensure the client can make an informed decision. This aligns with the principle of integrity and the duty to act in the best interest of the client.
Incorrect: Recommending a hybrid approach primarily to satisfy sales targets compromises the duty of care and objectivity. Providing no recommendation fails the professional duty to provide advice that is in the best interest of the client as required under the FAA. Adhering only to internal guidelines or the bare legal minimum ignores the higher professional standards of the Code of Ethics, which demand prioritizing the client’s welfare over firm incentives.
Takeaway: The core of Singapore’s financial ethics is the ‘Client First’ principle, necessitating the prioritization of client needs over personal or institutional financial gain.
Incorrect
Correct: In Singapore, the Code of Ethics and the MAS Fair Dealing Guidelines require financial advisers to place the interests of their clients as their first priority. When a conflict arises between a firm’s commercial interests (such as sales targets or commissions) and the client’s specific needs (such as a buy-sell agreement structure), the adviser must provide objective advice and disclose the conflict to ensure the client can make an informed decision. This aligns with the principle of integrity and the duty to act in the best interest of the client.
Incorrect: Recommending a hybrid approach primarily to satisfy sales targets compromises the duty of care and objectivity. Providing no recommendation fails the professional duty to provide advice that is in the best interest of the client as required under the FAA. Adhering only to internal guidelines or the bare legal minimum ignores the higher professional standards of the Code of Ethics, which demand prioritizing the client’s welfare over firm incentives.
Takeaway: The core of Singapore’s financial ethics is the ‘Client First’ principle, necessitating the prioritization of client needs over personal or institutional financial gain.
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Question 18 of 28
18. Question
After identifying an issue related to Personal Data Protection Act (PDPA) obligations for handling client and employee data, what is the best next step? A financial advisory firm owner discovers that sensitive client financial assessments and employee medical certificates are stored on a shared office server accessible to all staff members, including those in non-related administrative roles.
Correct
Correct: Under the PDPA’s Protection Obligation, organizations in Singapore must make reasonable security arrangements to protect personal data in their possession or under their control to prevent unauthorized access, collection, use, or disclosure. Implementing role-based access controls is a fundamental security measure to ensure that sensitive data, such as financial assessments and medical records, is only accessible to employees who require it for their specific job functions. A DPIA is a recommended practice by the Personal Data Protection Commission (PDPC) to systematically identify and mitigate data protection risks.
Incorrect: Obtaining retrospective consent does not exempt an organization from the Protection Obligation; even with consent, the firm must still secure the data. Purging records after 24 months may lead to a violation of other Singapore regulations, such as the Financial Advisers Act (FAA), which typically requires records to be kept for at least five or six years. Transferring data to an overseas cloud provider does not absolve the Singapore organization of its liability; under the Transfer Limitation Obligation, the firm must ensure the overseas recipient provides a standard of protection comparable to the PDPA.
Takeaway: The PDPA Protection Obligation requires Singapore businesses to implement reasonable security measures, such as restricted access controls, to prevent unauthorized internal and external access to personal data.
Incorrect
Correct: Under the PDPA’s Protection Obligation, organizations in Singapore must make reasonable security arrangements to protect personal data in their possession or under their control to prevent unauthorized access, collection, use, or disclosure. Implementing role-based access controls is a fundamental security measure to ensure that sensitive data, such as financial assessments and medical records, is only accessible to employees who require it for their specific job functions. A DPIA is a recommended practice by the Personal Data Protection Commission (PDPC) to systematically identify and mitigate data protection risks.
Incorrect: Obtaining retrospective consent does not exempt an organization from the Protection Obligation; even with consent, the firm must still secure the data. Purging records after 24 months may lead to a violation of other Singapore regulations, such as the Financial Advisers Act (FAA), which typically requires records to be kept for at least five or six years. Transferring data to an overseas cloud provider does not absolve the Singapore organization of its liability; under the Transfer Limitation Obligation, the firm must ensure the overseas recipient provides a standard of protection comparable to the PDPA.
Takeaway: The PDPA Protection Obligation requires Singapore businesses to implement reasonable security measures, such as restricted access controls, to prevent unauthorized internal and external access to personal data.
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Question 19 of 28
19. Question
A stakeholder message lands in your inbox: A team is about to make a decision about Workplace safety and health (WSH) regulations and employer liability as part of regulatory inspection at a fund administrator in Singapore, but the message highlights a disagreement regarding the scope of the Workplace Safety and Health Act (WSHA) for office-based environments. The Compliance Officer notes that since the firm primarily handles digital assets and fund administration, the physical risks are minimal compared to construction sites. However, a recent internal audit identified ergonomic issues and stress-related health concerns among the 50-person staff. Under the Singapore Workplace Safety and Health Act (WSHA), which of the following best describes the employer’s legal obligation regarding risk assessment in this office setting?
Correct
Correct: Under the Singapore Workplace Safety and Health Act (WSHA), every employer has the duty to take reasonably practicable measures to ensure the safety and health of employees. This includes conducting risk assessments to identify hazards (including ergonomic and psychosocial risks) and implementing control measures. The WSHA applies to all workplaces in Singapore, including office-based fund administrators, and does not exempt low-risk environments from the requirement to manage risks.
Incorrect: The claim that risk assessments are only mandatory for high-risk industries is incorrect because the WSHA covers all workplaces in Singapore. The suggestion that employers are only liable for physical injuries is false, as the definition of health under the WSHA includes both physical and mental well-being. The idea that senior management is absolved of liability by appointing a coordinator is incorrect; under Section 48 of the WSHA, directors and officers can be held personally liable if an offense is committed with their neglect, consent, or connivance.
Takeaway: The Workplace Safety and Health Act (WSHA) requires all Singapore employers, including those in low-risk office environments, to conduct risk assessments and ensure the safety and health of their employees.
Incorrect
Correct: Under the Singapore Workplace Safety and Health Act (WSHA), every employer has the duty to take reasonably practicable measures to ensure the safety and health of employees. This includes conducting risk assessments to identify hazards (including ergonomic and psychosocial risks) and implementing control measures. The WSHA applies to all workplaces in Singapore, including office-based fund administrators, and does not exempt low-risk environments from the requirement to manage risks.
Incorrect: The claim that risk assessments are only mandatory for high-risk industries is incorrect because the WSHA covers all workplaces in Singapore. The suggestion that employers are only liable for physical injuries is false, as the definition of health under the WSHA includes both physical and mental well-being. The idea that senior management is absolved of liability by appointing a coordinator is incorrect; under Section 48 of the WSHA, directors and officers can be held personally liable if an offense is committed with their neglect, consent, or connivance.
Takeaway: The Workplace Safety and Health Act (WSHA) requires all Singapore employers, including those in low-risk office environments, to conduct risk assessments and ensure the safety and health of their employees.
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Question 20 of 28
20. Question
Which statement most accurately reflects Singapore corporate tax rate and the partial tax exemption scheme for companies for ChFC06 Planning for Business Owners and Professionals in practice?
Correct
Correct: In Singapore, the corporate tax rate is a flat 17%. The Partial Tax Exemption (PTE) scheme is available to all companies (including companies limited by guarantee) unless they are already claiming the Tax Exemption Scheme for New Start-Ups. Under the PTE, 75% of the first $10,000 of normal chargeable income is exempt, and 50% of the next $190,000 is exempt. This results in a maximum exemption of $102,500 per Year of Assessment.
Incorrect: The assertion that the corporate tax rate is progressive up to 22% is incorrect, as Singapore maintains a flat 17% corporate rate regardless of company size. The claim that the PTE allows for 100% exemption on the first $100,000 is a confusion with the Tax Exemption Scheme for New Start-Ups (which itself only offers 75% on the first $100,000, not 100%). The suggestion that the tax rate is 15% or 20% is factually incorrect under current Inland Revenue Authority of Singapore (IRAS) regulations. Furthermore, the single-tier system refers to the fact that dividends are not taxed in the hands of shareholders once the company has paid tax on its profits, rather than how the PTE is applied.
Takeaway: Singapore’s corporate tax system features a flat 17% rate with a partial tax exemption scheme that reduces the effective tax rate on the first $200,000 of chargeable income for eligible companies.
Incorrect
Correct: In Singapore, the corporate tax rate is a flat 17%. The Partial Tax Exemption (PTE) scheme is available to all companies (including companies limited by guarantee) unless they are already claiming the Tax Exemption Scheme for New Start-Ups. Under the PTE, 75% of the first $10,000 of normal chargeable income is exempt, and 50% of the next $190,000 is exempt. This results in a maximum exemption of $102,500 per Year of Assessment.
Incorrect: The assertion that the corporate tax rate is progressive up to 22% is incorrect, as Singapore maintains a flat 17% corporate rate regardless of company size. The claim that the PTE allows for 100% exemption on the first $100,000 is a confusion with the Tax Exemption Scheme for New Start-Ups (which itself only offers 75% on the first $100,000, not 100%). The suggestion that the tax rate is 15% or 20% is factually incorrect under current Inland Revenue Authority of Singapore (IRAS) regulations. Furthermore, the single-tier system refers to the fact that dividends are not taxed in the hands of shareholders once the company has paid tax on its profits, rather than how the PTE is applied.
Takeaway: Singapore’s corporate tax system features a flat 17% rate with a partial tax exemption scheme that reduces the effective tax rate on the first $200,000 of chargeable income for eligible companies.
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Question 21 of 28
21. Question
After identifying an issue related to The impact of debt-to-equity ratios on business valuation for bank financing, what is the best next step? A Singapore-based SME owner is seeking a significant term loan from a local commercial bank for regional expansion. The financial advisor notes that the company’s debt-to-equity ratio has risen significantly above the industry average following a recent acquisition.
Correct
Correct: In the Singapore financial landscape, banks and financial institutions regulated by the Monetary Authority of Singapore (MAS) utilize a holistic credit assessment framework. When a debt-to-equity ratio is high, the best next step is to conduct a comparative analysis. This involves looking at the debt service coverage ratio (DSCR) and industry benchmarks to determine if the leverage is a result of strategic growth or financial instability. This helps the advisor understand how a lender will perceive the risk and the subsequent impact on the business’s valuation for collateral or loan-to-value purposes.
Incorrect: Reclassifying loans without proper legal standing or intent is a breach of financial reporting integrity and could be seen as misleading a financial institution. While future cash flow is important, Singapore banks do not ignore leverage ratios; they are a fundamental part of the risk-rating process. Liquidating core assets is an extreme measure that could impair the business’s ability to generate income and is not a standard first response to a high leverage ratio, nor is there an ‘automatic’ rejection based solely on a single ratio without context.
Takeaway: Effective business planning for financing requires a comparative analysis of leverage ratios against industry norms and debt-servicing capacity to accurately gauge a firm’s creditworthiness in the Singapore market.
Incorrect
Correct: In the Singapore financial landscape, banks and financial institutions regulated by the Monetary Authority of Singapore (MAS) utilize a holistic credit assessment framework. When a debt-to-equity ratio is high, the best next step is to conduct a comparative analysis. This involves looking at the debt service coverage ratio (DSCR) and industry benchmarks to determine if the leverage is a result of strategic growth or financial instability. This helps the advisor understand how a lender will perceive the risk and the subsequent impact on the business’s valuation for collateral or loan-to-value purposes.
Incorrect: Reclassifying loans without proper legal standing or intent is a breach of financial reporting integrity and could be seen as misleading a financial institution. While future cash flow is important, Singapore banks do not ignore leverage ratios; they are a fundamental part of the risk-rating process. Liquidating core assets is an extreme measure that could impair the business’s ability to generate income and is not a standard first response to a high leverage ratio, nor is there an ‘automatic’ rejection based solely on a single ratio without context.
Takeaway: Effective business planning for financing requires a comparative analysis of leverage ratios against industry norms and debt-servicing capacity to accurately gauge a firm’s creditworthiness in the Singapore market.
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Question 22 of 28
22. Question
An incident ticket at an audit firm in Singapore is raised about The use of a Trustee to hold insurance policies for succession funding during whistleblowing. The report states that a group of directors in a Singapore-based private limited company appointed one of their own fellow directors as the sole trustee for the insurance policies intended to fund a cross-purchase agreement. The whistleblower alleges that this arrangement, established three years ago, lacks sufficient oversight and creates a significant risk to the succession plan’s execution. What is the primary risk assessment concern regarding this specific trustee arrangement in the context of Singapore’s fiduciary and succession planning standards?
Correct
Correct: In Singapore, a trustee is bound by strict fiduciary duties under the Trustees Act and common law to act in the best interests of the beneficiaries. When a business partner serves as a trustee for insurance policies meant to fund a buyout of their own shares or those of their partners, a significant conflict of interest arises. This dual role can lead to disputes over share valuation or the timing of payouts, potentially jeopardizing the impartial execution of the buy-sell agreement during a critical succession event.
Incorrect: The suggestion that MAS would reclassify a private succession trust as a Collective Investment Scheme is incorrect as these trusts do not meet the definition of a CIS under the Securities and Futures Act. There is no specific provision in the SFA that mandates a licensed trust company based solely on a 100,000 Singapore Dollar premium threshold for private business arrangements. The Singapore Exchange (SGX) regulates listed companies, and its rules regarding public filings do not typically apply to the private trust deeds of a private limited company’s directors.
Takeaway: To ensure the integrity of a succession plan in Singapore, business owners should address potential conflicts of interest by considering the appointment of an independent or professional trustee to manage insurance-funded buy-sell agreements.
Incorrect
Correct: In Singapore, a trustee is bound by strict fiduciary duties under the Trustees Act and common law to act in the best interests of the beneficiaries. When a business partner serves as a trustee for insurance policies meant to fund a buyout of their own shares or those of their partners, a significant conflict of interest arises. This dual role can lead to disputes over share valuation or the timing of payouts, potentially jeopardizing the impartial execution of the buy-sell agreement during a critical succession event.
Incorrect: The suggestion that MAS would reclassify a private succession trust as a Collective Investment Scheme is incorrect as these trusts do not meet the definition of a CIS under the Securities and Futures Act. There is no specific provision in the SFA that mandates a licensed trust company based solely on a 100,000 Singapore Dollar premium threshold for private business arrangements. The Singapore Exchange (SGX) regulates listed companies, and its rules regarding public filings do not typically apply to the private trust deeds of a private limited company’s directors.
Takeaway: To ensure the integrity of a succession plan in Singapore, business owners should address potential conflicts of interest by considering the appointment of an independent or professional trustee to manage insurance-funded buy-sell agreements.
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Question 23 of 28
23. Question
A monitoring dashboard for a credit union in Singapore shows an unusual pattern linked to Insurance-linked employee retention plans and their vesting schedules during change management. The key detail is that several senior executives are concerned about the security of their unvested policy values following a proposed merger with a larger financial institution. The credit union’s board must decide how to handle the existing executive bonus plans, which utilize life insurance policies with a 5-year graded vesting schedule, to ensure talent stability during the 18-month integration period. Which approach to the vesting schedule best balances the interests of the business owners and the key professionals under Singapore’s corporate governance standards?
Correct
Correct: In the context of Singapore’s professional landscape, a double-trigger acceleration clause is considered a best-practice mechanism for executive retention during mergers. It protects the professional by ensuring they receive their benefits if their role is eliminated by the new entity, while also protecting the business owner by preventing a ‘windfall’ exit where the employee leaves voluntarily immediately after the merger simply because their benefits fully vested.
Incorrect: Immediate full vesting upon a merger announcement often leads to ‘walk-away’ risk, where key talent leaves at the most critical time because they no longer have a financial incentive to stay. Suspending vesting progress is likely to be viewed as a breach of the original employment agreement and could lead to constructive dismissal claims or a mass exodus of talent. Converting the plan to a discretionary cash bonus removes the long-term security and potential tax-deferred growth associated with insurance-linked plans, which were the primary reasons for choosing such a structure initially.
Takeaway: A double-trigger provision in insurance-linked retention plans effectively aligns executive and shareholder interests during corporate transitions by requiring both a change in control and a loss of employment for accelerated vesting.
Incorrect
Correct: In the context of Singapore’s professional landscape, a double-trigger acceleration clause is considered a best-practice mechanism for executive retention during mergers. It protects the professional by ensuring they receive their benefits if their role is eliminated by the new entity, while also protecting the business owner by preventing a ‘windfall’ exit where the employee leaves voluntarily immediately after the merger simply because their benefits fully vested.
Incorrect: Immediate full vesting upon a merger announcement often leads to ‘walk-away’ risk, where key talent leaves at the most critical time because they no longer have a financial incentive to stay. Suspending vesting progress is likely to be viewed as a breach of the original employment agreement and could lead to constructive dismissal claims or a mass exodus of talent. Converting the plan to a discretionary cash bonus removes the long-term security and potential tax-deferred growth associated with insurance-linked plans, which were the primary reasons for choosing such a structure initially.
Takeaway: A double-trigger provision in insurance-linked retention plans effectively aligns executive and shareholder interests during corporate transitions by requiring both a change in control and a loss of employment for accelerated vesting.
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Question 24 of 28
24. Question
In managing Asset protection strategies against creditors for business owners, which control most effectively reduces the key risk of assets being clawed back by a trustee in bankruptcy under the Insolvency, Restructuring and Dissolution Act (IRDA)?
Correct
Correct: Under Singapore’s Insolvency, Restructuring and Dissolution Act (IRDA), transactions at an undervalue can be set aside by a court if they occurred within specific look-back periods (generally 3 years for undervalue transactions) prior to the commencement of bankruptcy. For an asset protection strategy to be robust, the transfer must be made while the individual is solvent and not in anticipation of immediate litigation, ensuring the transfer is not deemed a voidable preference or a transaction intended to defraud creditors.
Incorrect: Transferring assets after receiving a demand letter is highly likely to be classified as a voidable preference or a transaction at an undervalue intended to defraud creditors, which a trustee in bankruptcy can easily reverse. Revocable trusts do not provide effective asset protection in Singapore because the settlor retains control and a beneficial interest, meaning creditors can often reach those assets. Commingling personal and business funds is a poor control as it may lead to ‘piercing the corporate veil’ and does not protect the owner from personal liabilities or guarantees already signed.
Takeaway: Effective asset protection in Singapore must be implemented proactively while solvent to avoid the clawback provisions of the Insolvency, Restructuring and Dissolution Act.
Incorrect
Correct: Under Singapore’s Insolvency, Restructuring and Dissolution Act (IRDA), transactions at an undervalue can be set aside by a court if they occurred within specific look-back periods (generally 3 years for undervalue transactions) prior to the commencement of bankruptcy. For an asset protection strategy to be robust, the transfer must be made while the individual is solvent and not in anticipation of immediate litigation, ensuring the transfer is not deemed a voidable preference or a transaction intended to defraud creditors.
Incorrect: Transferring assets after receiving a demand letter is highly likely to be classified as a voidable preference or a transaction at an undervalue intended to defraud creditors, which a trustee in bankruptcy can easily reverse. Revocable trusts do not provide effective asset protection in Singapore because the settlor retains control and a beneficial interest, meaning creditors can often reach those assets. Commingling personal and business funds is a poor control as it may lead to ‘piercing the corporate veil’ and does not protect the owner from personal liabilities or guarantees already signed.
Takeaway: Effective asset protection in Singapore must be implemented proactively while solvent to avoid the clawback provisions of the Insolvency, Restructuring and Dissolution Act.
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Question 25 of 28
25. Question
You are Priya Park, the risk manager at a wealth manager in Singapore. While working on Business interruption insurance and its role in disaster recovery during risk appetite review, you receive a board risk appetite review pack. The issue identified is that the firm’s current Business Interruption (BI) coverage is tied strictly to the physical restoration of the office premises in Raffles Place. The board is concerned that this may not align with the Monetary Authority of Singapore (MAS) Guidelines on Business Continuity Management, which emphasize operational resilience. What should Priya recommend regarding the selection of the Indemnity Period to ensure the firm is adequately protected during a disaster recovery phase?
Correct
Correct: In the context of Singapore’s insurance market and risk management practices, the Indemnity Period in a Business Interruption policy is the duration during which the insurer will compensate the business for lost income and increased costs. A common pitfall is choosing a period that only covers the time to rebuild or repair physical assets. For a wealth manager, the ‘tail’ of the loss—the time it takes to regain client trust, restore assets under management, and return to pre-loss turnover levels—often extends far beyond the physical repair of an office. Therefore, the period must reflect the time needed for full financial recovery.
Incorrect: Limiting the indemnity period to a specific technical Recovery Time Objective (RTO) like four hours is a misunderstanding of insurance; RTO is a target for system availability, whereas BI insurance covers financial loss which persists much longer. Setting the period to end exactly when a recovery site is operational ignores the ongoing loss of revenue and market share that occurs while the business is stabilizing. A fixed-sum payout triggered by regulatory notification is not a standard feature of Business Interruption insurance, which is an indemnity-based product requiring proof of actual financial loss resulting from a covered peril.
Takeaway: The indemnity period in Business Interruption insurance must account for the total time required for a business to return to its pre-disaster financial position, not just the duration of physical repairs.
Incorrect
Correct: In the context of Singapore’s insurance market and risk management practices, the Indemnity Period in a Business Interruption policy is the duration during which the insurer will compensate the business for lost income and increased costs. A common pitfall is choosing a period that only covers the time to rebuild or repair physical assets. For a wealth manager, the ‘tail’ of the loss—the time it takes to regain client trust, restore assets under management, and return to pre-loss turnover levels—often extends far beyond the physical repair of an office. Therefore, the period must reflect the time needed for full financial recovery.
Incorrect: Limiting the indemnity period to a specific technical Recovery Time Objective (RTO) like four hours is a misunderstanding of insurance; RTO is a target for system availability, whereas BI insurance covers financial loss which persists much longer. Setting the period to end exactly when a recovery site is operational ignores the ongoing loss of revenue and market share that occurs while the business is stabilizing. A fixed-sum payout triggered by regulatory notification is not a standard feature of Business Interruption insurance, which is an indemnity-based product requiring proof of actual financial loss resulting from a covered peril.
Takeaway: The indemnity period in Business Interruption insurance must account for the total time required for a business to return to its pre-disaster financial position, not just the duration of physical repairs.
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Question 26 of 28
26. Question
Excerpt from a transaction monitoring alert: In work related to The role of the Singapore Chartered Accountant (CA) in business valuation as part of change management at a credit union in Singapore, it was noted that a senior partner is reviewing the valuation report of a local SME for a potential acquisition. The partner must ensure the valuation adheres to the professional standards expected of a CA (Singapore) and the guidelines issued by the Institute of Valuers and Appraisers, Singapore (IVAS). Which of the following best describes the professional responsibility of a Singapore Chartered Accountant when determining the appropriate valuation approach for a business interest under the IVAS framework?
Correct
Correct: In Singapore, Chartered Accountants performing valuations are guided by the International Valuation Standards (IVS) as adopted by the Institute of Valuers and Appraisers, Singapore (IVAS). These standards require the valuer to consider the Market, Income, and Cost approaches. The selection of the most appropriate method involves professional judgment, taking into account the nature of the business, the purpose of the valuation, and the reliability of available data, rather than following a rigid hierarchy or a single mandated method.
Incorrect: The suggestion that the Monetary Authority of Singapore (MAS) mandates the Cost Approach for all private entities is incorrect, as valuation methodology is governed by professional standards (IVAS/ISCA) rather than a specific MAS mandate for all SMEs. Exclusively applying the Market Approach is inappropriate because it may not be the most relevant method if comparable data is scarce or if the Income Approach better reflects the company’s future earning potential. Relying strictly on historical audited statements without adjustments is incorrect in a valuation context, as ‘normalization’ adjustments are often necessary to reflect the true economic capacity of the business, which differs from purely historical accounting under SFRS.
Takeaway: A Singapore CA must evaluate the Market, Income, and Cost approaches and use professional judgment to select the most relevant valuation methodology for a specific business context.
Incorrect
Correct: In Singapore, Chartered Accountants performing valuations are guided by the International Valuation Standards (IVS) as adopted by the Institute of Valuers and Appraisers, Singapore (IVAS). These standards require the valuer to consider the Market, Income, and Cost approaches. The selection of the most appropriate method involves professional judgment, taking into account the nature of the business, the purpose of the valuation, and the reliability of available data, rather than following a rigid hierarchy or a single mandated method.
Incorrect: The suggestion that the Monetary Authority of Singapore (MAS) mandates the Cost Approach for all private entities is incorrect, as valuation methodology is governed by professional standards (IVAS/ISCA) rather than a specific MAS mandate for all SMEs. Exclusively applying the Market Approach is inappropriate because it may not be the most relevant method if comparable data is scarce or if the Income Approach better reflects the company’s future earning potential. Relying strictly on historical audited statements without adjustments is incorrect in a valuation context, as ‘normalization’ adjustments are often necessary to reflect the true economic capacity of the business, which differs from purely historical accounting under SFRS.
Takeaway: A Singapore CA must evaluate the Market, Income, and Cost approaches and use professional judgment to select the most relevant valuation methodology for a specific business context.
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Question 27 of 28
27. Question
Two proposed approaches to Criteria for the “Anderson Rules” regarding tax treatment of keyman policies in Singapore conflict. Which approach is more appropriate, and why? A Singapore-based private limited company is considering purchasing insurance on its Managing Director to mitigate the financial impact of their potential demise. Approach 1 suggests that the company should purchase a term life policy with no cash value, naming the company as the sole beneficiary to replace lost profits. Approach 2 suggests that a whole life policy with a significant cash value component is preferable so the company can eventually recoup the premiums, while still claiming a tax deduction for the premiums paid.
Correct
Correct: In Singapore, the tax treatment of keyman insurance is governed by the ‘Anderson Rules’ (derived from case law and adopted by IRAS). For premiums to be tax-deductible, the policy must meet specific criteria: it must be a term policy (no cash value or capital element), the purpose must be to replace lost profits arising from the death or disability of the key person, and the company must be the sole beneficiary and owner of the policy. If these conditions are met, the premiums are deductible, and any subsequent payout is treated as taxable income.
Incorrect: Approach 2 and the related options are incorrect because policies with a savings or capital element, such as whole life or endowment policies, do not qualify for tax deduction under the Anderson Rules as they are viewed as capital in nature. Assigning a policy to an employee or their family changes the nature of the contract from business protection to an employee benefit, which disqualifies the premium deduction. There is no specific ‘five times salary’ rule that serves as the primary criteria for deductibility; the structural nature of the policy (term vs. permanent) and the profit-replacement purpose are the governing factors.
Takeaway: To qualify for tax deductibility in Singapore under the Anderson Rules, a keyman policy must be a term insurance plan with no cash value, intended solely to replace business profits, with the employer as the beneficiary.
Incorrect
Correct: In Singapore, the tax treatment of keyman insurance is governed by the ‘Anderson Rules’ (derived from case law and adopted by IRAS). For premiums to be tax-deductible, the policy must meet specific criteria: it must be a term policy (no cash value or capital element), the purpose must be to replace lost profits arising from the death or disability of the key person, and the company must be the sole beneficiary and owner of the policy. If these conditions are met, the premiums are deductible, and any subsequent payout is treated as taxable income.
Incorrect: Approach 2 and the related options are incorrect because policies with a savings or capital element, such as whole life or endowment policies, do not qualify for tax deduction under the Anderson Rules as they are viewed as capital in nature. Assigning a policy to an employee or their family changes the nature of the contract from business protection to an employee benefit, which disqualifies the premium deduction. There is no specific ‘five times salary’ rule that serves as the primary criteria for deductibility; the structural nature of the policy (term vs. permanent) and the profit-replacement purpose are the governing factors.
Takeaway: To qualify for tax deductibility in Singapore under the Anderson Rules, a keyman policy must be a term insurance plan with no cash value, intended solely to replace business profits, with the employer as the beneficiary.
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Question 28 of 28
28. Question
A stakeholder message lands in your inbox: A team is about to make a decision about Work Injury Compensation Act (WICA) requirements for Singapore employers as part of model risk at a fund administrator in Singapore, but the message indicates confusion regarding which employees must be covered by mandatory insurance. The HR director is reviewing the payroll for 50 employees, including 10 administrative staff earning 3,000 dollars monthly and 5 office cleaners. They need to ensure compliance with the Ministry of Manpower (MOM) regulations to avoid penalties. Based on the current Work Injury Compensation Act (WICA) guidelines in Singapore, which of the following statements correctly identifies the employer’s mandatory insurance obligations?
Correct
Correct: Under the Work Injury Compensation Act (WICA) administered by the Ministry of Manpower (MOM), Singapore employers are strictly required to purchase insurance for two categories of employees: all employees doing manual work (regardless of salary) and all non-manual employees earning 2,600 dollars or less a month. While employers remain liable for WICA claims from non-manual employees earning more than 2,600 dollars, they are not legally mandated to buy insurance for them, though it is highly recommended.
Incorrect: The suggestion that coverage depends on residency or citizenship is incorrect because WICA applies to all employees under a contract of service regardless of nationality. The claim that insurance is only required for those earning above 2,600 dollars is the reverse of the actual law, which protects lower-wage non-manual workers. The idea that professional staff are exempt based on a company’s paid-up capital is not a provision under the Act; the mandatory insurance requirement is based on job nature and salary thresholds.
Takeaway: Singapore employers must maintain WICA insurance for all manual workers and any non-manual workers earning 2,600 dollars or less per month.
Incorrect
Correct: Under the Work Injury Compensation Act (WICA) administered by the Ministry of Manpower (MOM), Singapore employers are strictly required to purchase insurance for two categories of employees: all employees doing manual work (regardless of salary) and all non-manual employees earning 2,600 dollars or less a month. While employers remain liable for WICA claims from non-manual employees earning more than 2,600 dollars, they are not legally mandated to buy insurance for them, though it is highly recommended.
Incorrect: The suggestion that coverage depends on residency or citizenship is incorrect because WICA applies to all employees under a contract of service regardless of nationality. The claim that insurance is only required for those earning above 2,600 dollars is the reverse of the actual law, which protects lower-wage non-manual workers. The idea that professional staff are exempt based on a company’s paid-up capital is not a provision under the Act; the mandatory insurance requirement is based on job nature and salary thresholds.
Takeaway: Singapore employers must maintain WICA insurance for all manual workers and any non-manual workers earning 2,600 dollars or less per month.