The following has been circulated by email by remisier representatives who had two meetings with the Monetary Authority of Singapore on 17 February 2015 and 4 March 2015. We republish the content so investors and other parties can appreciate the remisiers' perspective, irrespective of whether they agree or not with the points below.


Points raised by us at the meetings

1. Rebuilding Trust In Our Markets & Ensuring A Level Playing Field For All

click-1a. Computerised Trading Systems - Is it a level Playing Field ? - Fine line between providing liquidity & influencing prices to a large extent. Proper Price-Discovery not taking place.

Willing Buyer Willing Seller Basis not functioning well as it is supposed to be.

b. IPO Process - At least 25% of shares issued to public for proper price discovery to take place

Should be Initial Public Offer instead of Initial Private Offer.

c. Short-Selling Reporting Requirements - Intra-day shorts to be excluded.

For mistakes on short-sales (for amounts less than S$50,000), reporting not required unless these "mistakes" are regularly made to circumvent this rule.

Uphold the uptick rule in shorting so as to prevent indiscriminate shorting and wealth destruction.

d. FT STI Index - Only 30 Stocks. Easy for large institutional funds to influence the Index.

3 banks make-up 32% of Index. 3 Banks & Sing Tel & Jardine Matheson make-up 50% of Index.

FT STI Index to be made-up of the 100 largest capitalized stocks with no individual stock weightage more than 5%. FT STI 3,365 points as @ 31st Dec 2014 , 6.25% increase in 2014

However, many of the 766 listings are lower & some small-caps even lower than 2009 lows.


2. Creating A Conducive Environment For Investing & Trading

a. Clients sitting for Exams - Do away with it

Simple 1 to 2 page Risk Disclosure Statement with risks clearly explained to investing public.

Risk is inherent in any investment. We cannot regulate risk.

Do away with Specified Investment Product & Excluded Investment Product Classifications.

b Teletext - Bring it back to the free-to-air channels. Savvy Senior Citizens have the time & money and very comfortable with Teletext.

c. Buy-in Process - Previously for mistakes made, it can be rectified the following day by buying back via Error-In-Trade A/C. Now, for mistakes made no avenue to correct it the next day.

Charges 0.75 % Brokerage fees + S$ 75 penalty fees inclusive of GST.

Also, if Buy-in not satisfied need to appeal for waiver of penalty S$ 1,000 or 5% of Contract value whichever higher. For mistakes on Buy-in market penalties of up to S$ 50,000 can be imposed. Also, even if a mistake to indicate as a CPF trade subject to Buy-in Process. Using a sledgehammer to whack a tiny ant.

money_animatedd. Cash Market - Creates more depth to the market.

It also provides investors an avenue to cover any accidental short-sales without subjecting themselves to the costly buy-in process.

Scrip Lending - creates a 2-way market - Currently SGX has this facility but some houses not providing it to due to cost concerns.

e. Bid - Spreads - Earlier Days, Less than S$1 - 0.5 cent, S$1 to S$3 - 1 cent, S$3 - S$5 - 2 cents,

S$5 to S$10 - 5 cents & S$10 or more 10 cents.

Now , Less than 20 cents - 0.1 cent, 20 cents to S$2 - 0.5 cent & S$2 or more - 1 cent.

Proposal - less than 10 Cents - 0.1 cent,10 cents to 20 cents - 0.2 cent,20 cents to S$1 - 0.5 cent

S$1 to S3 - 1 cent, S$3 to S$ 5 - 2 cents, S$5 to S$10 - 3 cents & S$10 & greater - 5 cents.

f. Dynamic Circuit Breaker - +/- 10% for equities above 50 cents but circuit breaker to be in place for 1 hour instead of 5 minutes for adequate dissemination of market information.

g. Cap of S$600 of clearing fees per counter per day should be re-instated. Only for Individual Omnibus Accounts & not Nominee Accounts. Improves liquidity of the market.

h. A minimum 5% Collaterised Trading creates more paperwork & confusion amongst the investing public. Either you have full Margin-based investing or the current system where the Broker who is worth his salt will be able to manage the risk. For Margin-based Investing reasonable interest must be given for cash balances sitting in the Margin Account.


3. Maintaining The Quality Of Our Listings

a. World-Class Government Linked Companies like PSA, PUB, PWD, Changi Airports International, Surbana etc to be considered. Creates more diversity & depth to our markets.

b. Cross-border listings within ASEAN - Initially Top 20 companies by Market-Cap.

Must have primary listing in Home Country & a secondary listings in the other ASEAN countries. Currently, China-based companies & to a lesser extent other countries are incorporated in Tax Heaven countries (Cayman Islands, British Virgin Islands).

For retail investors very difficult to seek recourse for Corporate Governance issues.

c. Creating A Third Board - Cash Upfront basis so less likelihood for prices to be manipulated.

Let the proper price-discovery process to take place with all relevant information disclosed.

Give a chance for companies to make a come-back when fundamentals improve.

Don't Give A Death Sentence But A Live-Sentence With A Chance For Parole.

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