Full versus Wholesale Banks – S’pore

Well simple things like discovering a difference really makes my day!

MAS = Monetary Authority of Singapore (Singapore’s central bank); SMEs = small and medium-sized enterprises.

The digital full-bank licence will allow licensees to provide a wide range of financial services and take deposits from retail customers. A digital wholesale bank licence will allow licensees to serve SMEs and other non-retail segments.

Singapore to issue up to five new licences to digital banks. Jamie Lee. (29 Jun 2019). The Business Times, Singapore.

Singapore’s central bank plans to issue up to five digital bank licences to suitable applicants, in a move that could deliver the biggest shake-up in two decades in a market dominated by local banks…

The central bank will also issue up to three digital wholesale bank licences which will be open to both local and foreign players.

Digital wholesale banks will not be allowed to take Singapore deposits from individuals, except for fixed deposits of at least S$250,000 and will be permitted to maintain deposit accounts for corporate and small and medium enterprises.

Singapore to allow virtual banks as part of a move to open up the market. (30 Jun 2019). Reuters via CNBC, US [ global headquarters in Englewood Cliffs, New Jersey]

See also:

The Banking Industry and the Major Players in Singapore. (no date / acessed 29 Jul 2019). GuideMeSingapore / Hawksford. 16 Raffles Quay, #32-03 Hong Leong Building, Singapore, 048581.

Business Diversification

In response to the announcement, gaming peripherals brand Razer’s chief strategy officer Limeng Lee said MAS was “forward-looking” in “opening up more financial options to consumers and businesses”. The announcement is timely as Razer has been growing its financial technology business in South-east Asia in recent months, he added. “We will definitely consider applying for the digital bank license and are keen to help spur innovation in Singapore’s financial sector,” Mr Lee said.

A Singtel spokesman said they are “open to exploring the feasibility of such an opportunity and will be reviewing the licensing conditions”.

Singapore to allow digital banks; MAS issuing up to 5 new licences: Tharman. (updated 29 Jun 2019). The Straits Times, Singapore.

The culture in Singapore seems to gravitate towards property investments whenever we have substantial excess cash.

SPH seems to have adopted this culture. It has built up a respectable property portfolio over past decades.

SPH (SGX:T39) – Is This The End for This Blue Chip Stock? Alvin Chow | Date: September 27, 2017. DrWealth. 71 Ayer Rajah Crescent #03-06, Singapore 139951.

The Edge Markets. (June 28, 2017). Why SPH needs to restructure itself. The Fifth Person.


3 Data Privacy Judgments – S’pore

For learning and prevention: 3 case studies [v.2 – 1 Aug 2019]

The first government judgment and warning relates to the popular messaging app, WhatsApp. The second judgment and fine involves email. The final judgment and warning concerns website security.

2     One of the many preschools under the Organisation’s management is the Sparkletots @ Kampong Chai Chee centre (the “preschool”). In the course of the year, the preschool would organise various school trips, sometimes with the participation of the parents. In preparation for these trips, the preschool would collect the parents’ personal data (including NRIC numbers) to allow for verification of the parents’ identity on the day of the trip.

3     The present investigations arise from one such school trip. A few days before the trip was scheduled to take place, a teacher at the preschool sent a photograph of a consolidated attendance list to a “WhatsApp” chat group, reminding parents of the upcoming school trip. The attendance list contained personal data relating to the 15 students in that particular class and their parents, and included the contact numbers and NRIC numbers of five of the parents (the “Personal Data”). The “WhatsApp” chat group comprised… parents of students from that class.

4     The teacher who sent the photograph of the attendance list quickly deleted it after being alerted to the disclosure of personal data by one of the parents within the group chat. That same parent later lodged a complaint with the Personal Data Protection Commission (“PDPC”). The PDPC thereafter commenced investigations into the incident…

8     After a review of all the evidence obtained by PDPC during its investigation and for the reasons set out below, I am of the view that the Organisation had failed to make reasonable security arrangements to protect the personal data in its possession and control, and has thereby breached the Protection Obligation under section 24 of the PDPA. This breach is attributable primarily to the Organisation’s lack of specific policies or procedures in place to guide its employees on the use, handling and disclosure of personal data, especially in the context of communicating with parents…

16     To  its  credit, the  Organisation also  acted swiftly  to  address their inadequate  policies – a  response  which,  in my assessment,  carries  mitigating value. The following remedial actions taken by the Organisation have therefore been taken into account:

(a) Immediate suspension of all “WhatsApp” chat groups following the disclosure;

(b) Expedited the implementation of a set of “Social Media Policy / Whatsapp chat group rules” that was already under development when the breach occurred;

(c) Rolled out a suite of other policies across the Organisation including a “Document Retention Policy” and an “Information Security Policy”; and

(d) Undertook the development of a practical employee handbook and conducted refresher training for its employees.

17     Having considered all the relevant factors of the case, I am of the view that these remedial actions have sufficiently addressed the current gap in policies and practices relating to the handling of personal data by the Organisation’s employees. I have therefore decided to issue a warning to the Organisation for breaching its obligations under section 24 of the PDPA, without further directions or imposing a financial penalty.

PAP Community Foundation [2019] SGPDPC6 (CaseNoDP-1807-B2434). Personal Data Protection Commission. (23 Apr 2019). https://www.pdpc.gov.sg/-/media/Files/PDPC/PDF-Files/Commissions-Decisions/Grounds-of-Decision—PAP-Community-Foundation—230419.pdf. Singapore.

2     On 27 November 2017, the Personal Data Protection Commission (the “Commission”) received notification from the Institute of Singapore Chartered Accountants (“ISCA”) that one of its employees inadvertently sent an email attaching a Microsoft Excel document containing personal data of 1,906 individuals (the “Excel File”) to an unintended recipient (the “Incident”)…

5     On or about 23 November 2017, as part of business operations, 2 ISCA employees (the “First Employee” and the “Second Employee”, collectively the “Employees”) were unable to open the Excel File (stored on ISCA’s internal shared drive) as it appeared to be corrupted. The Employees sought the assistance of ISCA’s IT department. Arising from this, ISCA’s IT Support Specialist sent an email to the System/Network Engineer from the ICT department to recover the Excel File from the backup server, and to send the recovered Excel File to the Employees.

6    On 24 November 2017, the System/Network Engineer created an email to send the recovered Excel File as an attachment to the Employees (the “Subject Email”). As the earlier email from the IT Support Specialist did not include the Employees in the addressee list, the System/Network Engineer had to specifically insert the Employees in the recipient section of the Subject Email. Due to the auto-complete feature in Microsoft Outlook’s email software, the System/Network Engineer inadvertently selected an accounts manager (the “Unintended Recipient”) 1 in a listed telecommunications service provider (“Telco”) instead of the First Employee as they both had the same first name. The Subject Email containing the Excel File was therefore sent to the IT Support Specialist, the Second Employee and the Unintended Recipient. The Excel File was not encrypted with a password…

18     The Commissioner found that ISCA failed to put in place reasonable security arrangements to protect the Subject Data in the Excel File during email transmission for the following reasons:

(a) The volume (1,906 members) and type (data with a higher expectation of confidentiality) of Subject Data in the Excel File warranted direct protection. In this regard, ISCA should have had a policy/SOP that applied to all employees requiring password based encryption for the Excel File in respect of both external and internal emails. This would be a reasonable security arrangement to protect the Subject Data against unauthorised access in the event the Subject Email was sent to any unintended recipient…

23     Having considered all the relevant factors of this case, the Commissioner hereby directs ISCA to do the following:

(a) Within 90 days from the date of the Commissioner’s directions, review its policies and security arrangements in respect of electronic transmission of documents containing personal data; and

(b) Pay  a  financial  penalty  of  S$6,000.00  within  30 days  from  the date of the Commissioner’s direction, failing which, interest at the rate specified in the Rules of Court3 in respect of judgment debts, shall accrue and be payable on the outstanding amount of the financial penalty until the financial penalty is paid in full.

Institute of Singapore Chartered Accountants [2018] SGPDPC 28. Personal Data Protection Commission. (13 Dec 2018). https://www.pdpc.gov.sg/-/media/Files/PDPC/PDF-Files/Commissions-Decisions/Grounds-of-Decision—Institute-of-Singapore-Chartered-Accountants—131218.pdf. Singapore.

2     On 8 June 2018, the Personal Data Protection Commission (the “Commission”) received a complaint from an individual (the “Complainant”) in relation to the publication of personal data belonging to 50 individuals on the Organisation’s website, http://www.tutorcity.com.sg (the “Website”). Specifically, images of the educational certificates of tutors using the Website were found to be publicly accessible by Internet users (the “Incident”)…

7     As part of the Website’s features, tutors interested in using the Organisation’s matching service are given the option of voluntarily uploading up to three different educational certificates onto the Website. These certificates assisted the Organisation in matching the needs of the student in question to suitable tutors. These certificates were not intended to be made publicly accessible.

8     Notwithstanding this, all uploaded certificates were stored in the /Public_html/directory (the “Public Directory”) of the Website’s server within a sub-folder, Public_html\tutor\tutor_image (the “Image Directory”). Both directories were not secured with any form of access controls and were accessible by the public so long as the path to the relevant directory was known…

21     In the present case, I am advised that where documents containing personal data have to reside on web servers, folder or directory permissions and access controls are a common and direct way of preventing their unauthorised access by public users and web crawlers. Depending on its circumstances, the Organisation could therefore have implemented any of the following reasonable technical security measures to prevent its Image Directory from being indexed by web crawlers:

(a) First, the Organisation could have placed these documents in a folder of a non-public folder/directory. Access to such documents will then be controlled by the server’s administrator. While this may not be ideal in complex servers with multiple web applications—given that it may not be practicable for the server administrator to control access to all these files—this is not the case for the present Website.

(b) Second, the Organisation could have placed these documents in a folder of a non-public folder or directory, with access to these documents being through web applications on the server. This could be done through PHP scripts. To access the data in the documents, users would have to first log into the web application.

(c) Third, the Organisation could have placed these documents in a sub-folder within the Public Directory but control access to files by creating a .htaccess file within that sub-folder. This .htaccess file may specify the access restrictions (e.g. implement a password requirement or an IP address restriction). An index.html file  could  also  be  created  within  that  sub-folder  to  show  a  HTML page  with  no  content  or  a  denial  of  access. Any  unauthorised  user would  then  need  the  specific  URL  to  access  a document in  the  sub-folder. However, given that the Public Directory is the web root directory containing all  the  content  to  be  displayed  on  the  Website,  it  should  not  have  overly restrictive  access  rights.  This  may  pose  some  challenges  for organisations seeking  to  balance  access  restrictions  to  specific  documents  against  retaining accessibility to website content that is intended to be public…

27    I find on the facts above that the Organisation did not make reasonable security
arrangements to protect personal data in its possession or under its control against the risk of unauthorised access. The Organisation is therefore in breach of section 24 of the PDPA. I took into account the number of affected individuals, the type of personal data at risk of unauthorised access and the remedial action by the Organisation to prevent recurrence. I have decided to issue a warning to the Organisation for the breach of its obligation under section 24 of the PDPA as neither further directions nor a financial penalty is warranted in this case.

Tutor City [2019] SGPDPC 5 (Case No DP-1806-B2228). Personal Data Protection Commission. (23 Apr 2019). https://www.pdpc.gov.sg/-/media/Files/PDPC/PDF-Files/Commissions-Decisions/Grounds-of-Decision—Tutor-City-230419.pdf. Singapore.


…The absence of a second layer of basic checks “amounted to extremely weak internal work process controls (that) fell far short of the standard of protection required for such sensitive personal data”, said PDPC deputy commissioner Yeong Zee Kin in a decision paper issued on Wednesday…

In its advisory guidelines, PDPC had recommended that paper containing personal information be shredded into small pieces and not dumped in unsecured bins.

Similarly, personal data stored on electronic media such as computer hard disks, USB drives or DVDs must be erased using specialised software to avoid accidental data leaks.

Aviva fined $6,000 for data breach. Irene Tham. (Oct 13, 2017). https://www.straitstimes.com/tech/aviva-fined-6000-for-data-breach. The Straits Times. Singapore.

Aviva’s most recent offence involved four underwriting letters meant for four different people to a single person, all contained in one envelope. The letters contained client’s full names, addresses, policy details, and sums assured.

“[Aviva] failed to conduct a more thorough review of its internal departments… that are subject to the same vulnerabilities and risk similar failures as the prior incident,” PDPC said…

Meanwhile, AIG had printed a wrong fax number, which was actually that of Japanese products retailer Tokyu Hands, on 125 policy letters. PDPC said that AIG policyholders could have mistakenly sent their personal data to Tokyu Hands due to the misprint.

Singapore’s privacy watchdog fines three insurers for data breaches. Gabriel Olano. (5 May 2018). https://www.insurancebusinessmag.com/asia/news/breaking-news/singapores-privacy-watchdog-fines-three-insurers-for-data-breaches-99807.aspx. Insurance Business Asia.

Data Privacy Changes – 2019 – S’pore

Currently, there are no mandatory requirements under the Act for data users to notify the Commission or individuals regarding data protection breaches in Singapore. The Commission issued a best practice guide in May 2015 to help organizations manage personal data breaches effectively, and more recent guidelines provide practical tips on avoiding and managing risks such as accidental data disclosure. It is recommended that affected individuals be notified immediately if a data breach involves sensitive personal data. The Commission should be notified as soon as possible of any data breaches that might cause public concern or where there is a risk of harm to a group of affected individuals. Aggrieved parties may either make a complaint to the Commission, or may take out a private action in civil proceedings.  The Commission may also conduct investigations on its own motion.

However, there are now proposals to introduce mandatory data breach notifications in Singapore. It is anticipated that the Act will be amended sometime in 2019 to incorporate the amendments proposed in the PDPA Consultation. Organizations are advised to monitor developments.

In addition, the Cybersecurity Act 2018 (CSA) was recently passed in Parliament, and sections of the CSA have now come into force. As at the date of this update, the obligations under the CSA primarily fall on organizations which have been designated as owners of critical information infrastructure. If your organization has been designated by the Cybersecurity Commissioner as the owner of a critical information infrastructure, additional obligations will apply to your organization in relation to data breach incident handling and notification. 

[Words in bold – my additions] DLA Piper (a global law firm). Singapore. https://www.dlapiperdataprotection.com/index.html?t=breach-notification&c=SG. (updated 28 Jan 2019).


Privacy watchdog starts public consultation on data law changes. (22 May 2019). The Straits Times. Singapore.

Merging Business with Compliance

Efforts to improve employee health and safety by depicting related changes as profitable…


WSH 2028 = Workplace Safety and Health

Promoting Benefits and Recognizing Best Practices

…This was another important strategy which was pursued and implemented. The aim was to promote a better understanding of the benefits of good WSH performance among employers. WSH was shown to enhance business value by creating a good corporate image, and results in cost savings through higher productivity and reduced work disruptions from accidents. Sharing of best practices was encouraged to promote cross industry learning and to facilitate an environment of continuous improvement.

Can We Reduce Workplace Fatalities by Half? David Soo Quee Koh. (Received 23 November 2011, Revised 6 January 2012, Accepted 19 January 2012, Available online 17 July 2013). https://doi.org/10.5491/SHAW.2012.3.2.104. Science Direct.

…There is also a strong focus on enhancing workforce health and the use of technology for safe work practices.

…First, WSH 2028 places a bigger onus on prevention of work injuries and diseases by employers and workers than before.

New measures include sharing work injury compensation claims data for differentiated insurance premiums based on a company’s safety record and public-sector developers harmonising the disqualification criteria for contractors.

…A more positive measure in WSH 2028 is the call for companies to develop guidelines on job adaptations for workers with chronic diseases such as diabetes.

[Dr Gan Wee Hoe is Vice President of the College of Public Health and Occupational Physicians, Academy of Medicine Singapore. Dr Chia Kee Seng is Professor at the Saw Swee Hock School of Public Health, National University of Singapore.] Why Singapore’s new approach to workplace safety and health matters (to you). TODAY. https://www.todayonline.com/commentary/why-singapores-new-approach-workplace-safety-and-health-matters-you. (15 Apr 2019). Singapore.

References / Other compliance examples

Research Case Study: WSH / 2012

“If we knew what we were doing it wouldn’t be research.” – Albert Einstein

“By seeking and blundering we learn.” – Johann Wolfgang von Goethe

Famous Quotes on Research and Well-Being. (17 Oct 2017). Whitney Hopler. https://wbu.gmu.edu/famous-quotes-on-research-and-well-being/. George Mason University.

I believe this is what research looks like in real life…


WSH = workplace safety and health

Confound = [cause surprise or confusion in (someone), especially by not according with their expectations. (accessed 7 Jun 2019). https://en.oxforddictionaries.com/definition/confound]

Koh, David Soo Quee. “Can we reduce workplace fatalities by half?.” Safety and health at work vol. 3,2 (2012): 104-9. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3440458/. National Center for Biotechnology Information, U.S. National Library of Medicine. 8600 Rockville PikeBethesda MD20894 USA. 

When considering an answer to the question “Can we reduce workplace fatalities by half?”, several questions can be raised. Possibly the two most pertinent considerations are what is the parameter being measured, and how long is the time frame for the change to occur.

Firstly, which parameter is being measured? Do we measure the absolute number of fatalities in the workplace, or the rate of workplace fatalities…

Secondly, what time frame should be allocated for the reduction in fatalities to occur by half? An ideal time frame is one which is challenging and ambitious, but yet is also realistic and within reach…

This paper described the experience of Singapore in reducing the national workplace fatality rate from 4.9 per 100,000 workers in 2004, when there were 83 fatalities, to 2.2 per 100,000 workers in 2010, when there were 54 workplace deaths…

With the introduction of all the above measures, which is much more than the activities and actions implemented before 2004, the workplace fatality rate declined steadily from 4.9 per 100,000 workers in 2004 to 2.2 per 100,000 in 2010 (Table 3) [7-9]. The workplace fatality rate was halved by 2010, and this achievement was attained 5 years ahead of the original target date that was set.

Several potential confounding factors could account for the reduction in fatalities observed. For example, factors which impacted the fatality rate could be due to changes in the reporting systems, or inconsistencies and misreporting of events regarding fatal workplace events. However, there were no changes in the reporting system for workplace fatalities in Singapore over these years, and fatal workplace accidents are usually completely captured in the notification system within this small country. Another confounding factor could be a change in the composition of the workforce over that period of time, e.g., an increase in the workforce proportion of multinational companies, which have their own health and safety systems generally having better safety and health performance, could result in a lowering of workplace fatality rates. The level of worker representative involvement in driving up health and safety performance could yet be another factor resulting in an improvement regarding fatality rates.

In addition, other parameters, if available, would provide further objective evidence to support the hypothesis that the interventions described produced the effect observed. Such supporting evidence could include: (a) how the work of the additional WSH professionals with the Ministry of Manpower was organized to deliver the desired outcomes, (b) how the number of duty holder interactions was affected, and (c) the number of enforcement measures over the period, e.g., the issuing of advisory letters, warning letters and notices of non-compliance and stop work orders. Unfortunately, such information during 2004-2010 was not available in the public domain. Additionally, surveys on awareness of WSH regulations could have been carried out over the period to show that the information provided by the enforcing authorities was being used and understood by the duty holders…

Additional analysis / related

  • [In summary, if you are able to prove that your employer or someone else was to blame for your accident, or if your injuries have long-lasting consequences, you may wish to file a lawsuit as this can allow you to recover a larger sum. But if you are unable to prove that your employer was at fault, it may be preferable for you to make a WICA claim.] Workplace Safety, Injuries, & The Law: A Practical Guide – Part Three. Viviene Sandhu. (February 13, 2018). https://learn.asialawnetwork.com/2018/02/13/workplace-safety-injuries-law-practical-guide-part-three/.

Advance Medical Directive and Death

Note: The law applies only to the Singapore context.

My own conclusion? Regardless of whether one signs the AMD (Advance Medical Directive), it would be good (in a practical sense) to discuss with your loved ones what to do when your death is about to happen. (I personally know someone who had already discussed death related matters with the children). For those without caregivers or family, the AMD may be even more urgent and crucial.


An Advance Medical Directive (AMD) is a legal document signed in advance, stating your personal decision to stop life-sustaining treatment if you become terminally ill, incapable of expressing decisions and death is imminent. Healthcare professionals can access it only when you are terminally ill, provided they are informed about it.

[Ref: N18] Advance Care Planning (ACP) and Advance Medical Directive (AMD): What is the Difference? (accessed 1 May 2019). Shi Jin, Senior Advance Care Planning Coordinator (Sengkang General Hospital). https://www.healthxchange.sg/seniors/ageing-concerns/advance-care-planning-advance-medical-directive.

Under the act, an AMD can only be executed when a patient is certified with a terminal illness; needs extraordinary life-sustaining treatment; and is not capable of making rational judgment. After the AMD has taken effect, a patient with terminal illness will still receive palliative care and medication. [Footnote 5]

Advance Medical Directive. Joycelyn Hwang. (2016). http://eresources.nlb.gov.sg/infopedia/articles/SIP_543_2004-12-18.html. Singapore Infopedia, National Library Board. 

…from the inception of the Advance Medical Directive (AMD) in 1997 until last year, 24,682 Singaporeans had made an AMD. During this period, 10 AMDs were put into effect.

Seeing dad suffer, made doctor sign the AMD himself. Toh Ting Wei. (27 Jul 2016). https://www.tnp.sg/news/singapore/seeing-dad-suffer-made-doctor-sign-amd-himself. The New Paper. 

Actual wording for AMD Form 1 (selection) 

1. I hereby make this advance medical directive that if I should suffer from a terminal illness and if I should become unconscious or incapable of exercising rational judgment so that I am unable to communicate my wishes to my doctor, no extraordinary life-sustaining treatment should be applied or given to me.

2. I understand that “terminal illness” in the Advance Medical Directive Act 1996 means an incurable condition caused by injury or disease from which there is no reasonable prospect of a temporary or permanent recovery where – (a) death would within reasonable medical judgment be imminent regardless of the application of extraordinary life-sustaining treatment; and (b) the application of extraordinary life-sustaining treatment would only serve to postpone the moment of death.

3. I understand that “extraordinary life-sustaining treatment” in the Advance Medical Directive Act 1996 means any medical procedure or measure which, when administered to a terminally ill patient, will only prolong the process of dying when death is imminent, but excludes palliative care.

4. This directive shall not affect any right, power or duty which a medical practitioner or any other person has in giving me palliative care, including the provision of reasonable medical procedures to relieve pain, suffering or discomfort, and the reasonable provision of food and water.

5. I make this directive in the presence of the two witnesses named on page 2.

[“AMD form” hyperlink] Ministry of Health, Singapore. (accessed 1 May 2019). Advance Medical Directive (AMD). https://www.moh.gov.sg/policies-and-legislation/advance-medical-directive

Case study without AMD

Patient was:

“supported by a ventilator with arms restrained”

“fed through a tube through his nostrils, with a catheter draining urine from his bladder”

affixed with a breathing tube “…down his windpipe, which prevented him from talking”

in a state where “…kidneys failed” and suffered “multiple internal bleeding”

The patient’s son stated: “It was bleak, everything in his body was already shutting down… The doctors could have continued to ventilate him, but it would have caused complications like bursting his lungs and further suffering. He would still have died in any case.”

It took a few days to make the choice to end the patient’s struggle and allow death to run its course. The patient’s son further added: “It was not a tough decision in some way. Maybe we should have stopped a bit earlier because he was suffering and his situation was utterly hopeless,”

[Edited for flow] Seeing dad suffer, made doctor sign the AMD himself. Toh Ting Wei. (27 Jul 2016).

Reason for registering AMD (with the Registrar of Advance Medical Directives)

Insurance agent Ngoh Seh Suan’s main concern in taking up the AMD was that he did not want to be a financial and emotional burden to his family.

The 36-year-old told TNP: “Before I signed the document, I asked myself if I can release my family of the emotional and financial decision (to pull the plug) in the worst case scenario for me.

“I don’t want to let them make this decision, it is not easy for them, and hence, I decided to do it myself.”

His parents did not oppose his decision when he broached the topic, but declined to sign it themselves.

His girlfriend, who declined to be named, agreed with his decision. She said: “I think it’s good that I don’t have to second-guess what Seh Suan might want. There is also a sense of peace knowing that it’s that person’s decision.”

Seeing dad suffer, made doctor sign the AMD himself. Toh Ting Wei. (27 Jul 2016).

Alternative Investing – Minterest

Minterest runs “a marketplace funding platform, connecting corporate borrowers with investors.” [https://www.minterest.sg/about, accessed 10 Apr 2019] It was one recipient of the Dun & Bradstreet Business Eminence Awards 2019. This was featured in the print copy of The Business Times, Singapore on 21 Mar 2019, p.10.

I selected some replies to online queries for potential investors below. It pleases me to learn about these things as well. Hope it helps you : )

Are there any fees payable by me?

Investors do not pay any fees for participating in the Funding Requests or for using the platform. However, a service fee of 15% will be levied on interest, factoring fees and any other fees earned by investors. All interest rates quoted on our platform are on a gross basis and payable to the investors to after deducting the service fee. There may be a small transactional fee imposed by the bank when withdrawals are made.

How is the contract signing done?

There is no physical signing of contracts. By clicking and agreeing to our platform terms, you are bound by the terms governing borrowers and lenders. This has the same legal effect as signing a contract.

What is an escrow agent?

Generally, an escrow agent is someone that holds property or money on behalf of someone while a transaction is being finalised. In our context, the escrow agent holds the investors’ money on their behalf before the investors participate or invest in a Loan Request. It will also hold money on behalf of the investors when the loans are repaid prior to it being used for further investments or withdrawn from the escrow agent’s bank account.

Will I earn interest on the money placed with Minterest?

Money placed in the escrow agent’s account will not earn any interest. You will earn interest from successfully participating in funding requests that are posted on our platform.

Would my return on investment be taxable?

You will earn interest and fee income from the investments that you make on our platform. We understand that interest and fee income earned from such investments are taxable under the laws of Singapore. You should consult your tax adviser if you are unclear about your tax obligations.  If you are a non-resident, you may also be subject to withholding tax on the interest or fee.

FAQ – Investors. (accessed 10 Apr 2019). https://www.minterest.sg/faq#faq-2.