Policies and Procedures for CMS licence holders/RFMC

The board of directors should approve the policies of the financial institutions (para. 2.1.2 Guidelines on Internal Controls).

The board of directors or senior management should periodically review the code of conduct in light of changes in the internal and external environment (para. 2.2.6 Guidelines on Internal Controls).

The procedural manuals should be periodically reviewed to ensure that they reflect current practices (para. 2.1.3 Guidelines on Internal Controls). MAS regulations do not prescribe a specific frequency for the review of the policies or procedures, including the code of conduct.

The policies and procedures must be reviewed upon a trigger event such as changes in applicable regulations, or changes in the operations or processes of the financial institution. Without such changes due to a trigger event, we are observing a market practice of reviewing policies and procedures every year or second year. A risk-based approach to the frequency may be considered.