Important Information on Accredited Investor (AI) Regime

1.         For Your Information

Shareable Assets Pte. Ltd. is required under Singapore lawto provide you with certain information before you make a decision on whether you wish to continue to be treated as an accredited investor as defined in section 4A of the Securities and Futures Act (Cap. 289) (the “SFA”).Accordingly, we hereby inform you that:

a.  we have assessed you to be an “accredited investor” as defined in section 4A of the SFA based on the information you have provided to us;

b.  you may, but are not obliged to, consent to being treated by us as an accredited investor for the purposes of the statutory provisions set out in regulation 3(9) of the Securities and Futures (Classes of Investors) Regulations 2018; and

c.  if you consent to the treatment outlined in paragraph (b) above, you may withdraw your consent at any time, upon which we will cease to treat you as an accredited investor after we have confirmed to you in writing your removal of accredited investor status.

General Warning: Accredited investors are assumed to be better informed, and better able to access resources to protect their own interests, and therefore require less regulatory protection. Investors who agree to be treated as accredited investors therefore forgo the benefit of certain regulatory safeguards. For example, issuers of securities are exempted from issuing a full prospectus registered with the Monetary Authority of Singapore in respect of offers that are made only to accredited investors, and intermediaries are exempted from a number of business conduct requirements when dealing with accredited investors. Investors should consult a professional adviser if they do not understand any consequence of being treatedas an accredited investor.

2.         Regulatory Safeguards that do not extend to AIs

Where we as a Capital Market Services Licensee (“CMSL”) deal with you as an Accredited Investor (AI), we would be exempt from complying with certain requirements under the Securities and Futures Act, Chapter 289 of Singapore (“SFA”) and certain regulations and notices issued there under. Please note that the regulatory requirements that we are exempted from when dealing with you as an Accredited Investor may be amended and updated from time to time due to regulatory changes or otherwise. We have summarised the requirements below.

Retail Investor
Accredited Investor
Prospectus Exemptions under Sections 275 and 305 of the SFA

The issuer/offeror is exempted from registering a prospectus when the offer of securities and securities-based derivatives contracts, and units of collective investment schemes is made to relevant persons. 

Secondary sale restriction and prohibition from being a transferee within 6 months after securities, securities-based derivative contracts, units of CIS are acquired by the Corporation or interests in the Trust.

The issuer/offeror is exempted from registering a prospectus when the offer of securities and securities-based derivatives contracts, and units of collective investment schemes is made to relevant persons. Relevant persons include Accredited Investors.

No restriction on secondary sale and prohibition from being a transferee of the Corporation or interests in the Trust.

Restrictions on  Advertisements under Sections 251 and 300 of the SFA

Prohibit any advertisement or publication referring to an offer or  intended offer of securities and securities-based derivatives contracts, and units of collective investment schemes from being made.

Dissemination of, and presentation of oral or written material on matters  contained in, the preliminary document (prior to prospectus registration) which has been lodged with the MAS to institutional investors and relevant persons. Relevant persons include Accredited Investors.

Customer’s  Moneys under Part  III, Division 2 of SFA (Licensing and Conduct of Business)

The CMSL to make certain disclosures (such as whether the moneys will be commingled with other customers and the risks of commingling, consequences if the CMSL which maintains the trust account  becomes insolvent) in writing prior to depositing moneys in trust account.

No such requirement.

The CSML is not permitted to transfer retail  investor’s moneys from trust account, to meet any obligation of the CMSL in relation to any transaction entered into by CMSL for the benefit of the CMSL.

No such prohibition.

Deposit moneys received on account of its customers into a trust account maintained in accordance with Regulation 17 of the SFA with specified financial institutions or;

Deposit into account directed by retail customer to which retail customer has legal and beneficial title and maintained with, inter alia, licensed banks, merchant banks or finance companies or banks established and regulated as banks outside Singapore.

Deposit moneys received on account of its customers into a trust accountmaintained in accordance with Regulation 17 of the SFA with specified financial institutions or;

Deposit into account directed by Accredited Investor.

Provision of  Account Statement under s(40) Part IV of SFA (Licensing and Conduct of Business)

CMSL is required to furnish to each customer, a statement of account monthly/quarterly, containing certain particulars and, where applicable, the assets, derivatives contracts of the customer that are outstanding and have not been liquidated and cash balances (if any) of the customer at the end of that quarter.

No such requirements, and provided the CMSL has made available (on a real-time basis) the prescribed particulars of account  in the form of electronic records stored on an electronic facility, or have requested to CMSL in writing not to receive the statement of account.