Fair dealing outcomes: what MAS's five mean in your sales week

Fair dealing outcomes are the five results that MAS's Guidelines on Fair Dealing expect every financial institution to deliver to its customers. Put plainly: clients can trust that treating them fairly sits at the centre of the firm, what they're offered suits them, the person advising them knows the job, they get information they understand in time to use it, and a complaint gets a fair and quick hearing. MAS last revised the Guidelines on Fair Dealing, numbered FSG-G04, on 30 May 2024.

MAS addresses the document to boards and senior management, which makes it easy for an advisor to skip. Skip it and you miss that MAS defines a representative as any staff, employee or agent a financial institution engages, and nearly every outcome is won or lost in a room with one client and one advisor. That's you at the fact-find. It's you again on WhatsApp the evening after, and on the phone when something goes wrong.

The third column is the part you control.

MAS first issued the Guidelines on 3 April 2009. Its media release that day tied them to the Financial Advisers Act and to investment products: picking them, marketing them, advising on them, after-sales service and complaints. The same release said MAS would consider a firm's ability or failure to observe the Guidelines when judging whether it stays fit and proper to conduct regulated activities. They're guidelines rather than an Act, and that sentence is why firms treat them as rules anyway.

The 2024 revision widened them. The Guidelines now apply across all financial products and services, from product design to marketing, sales, after-sales service and complaints, and MAS's page for them lists who they apply to: licensed and exempt financial advisers, banks, trust businesses, capital markets services firms, payment firms, insurers and insurance brokers. They were written mainly with retail customers in mind, but MAS expects the principles applied to every customer. Each firm meets them in proportion to its business model, what it sells and how much harm a client could suffer, with extra care for customers who are more vulnerable.

For a financial advisor, three things follow. A wealthy client doesn't take the conversation outside the outcomes. A product your firm didn't design is still yours to explain properly. And your supervisor's duties under outcome 3 are written down, so you can ask for them.

On 26 May 2026 MAS published an information paper on market conduct controls in the financial advisory industry, drawn from a 2025 survey of selected firms. Its first section is prospecting, and the firms it praised did three things there:

• Advisors put their name and representative number on their social media accounts and digital ads, so anyone can check them.
• Advisors got approval before using marketing material they made themselves, and sent in a screenshot and the link to a live ad within 3 days of posting it.
• Advisors and leaders who used crowd pullers at a roadshow trained before each one, and the booth showed a QR code for on-the-spot feedback.

The Guidelines add the rule that matters on every first call: no pressure. MAS tells firms to stop advisors overplaying a time-limited offer ("only for today"), to give clients enough time to understand what they've been told and think about it, and not to use gifts or rebates to steer the decision. If your opener leans on a deadline, rewrite it this week.

Two checks before a cold message goes out. A number from a list gets a DNC Registry check before you send anything that markets. And open the first message with your name, your firm and your representative number, so the client can check you before they reply. The reminder the day before and the nudge to a client who's gone quiet are ready to copy in the WhatsApp messages for financial advisors.

Outcome 2 is mostly your firm's job: test a product before launch, work out which customers it suits and which it clearly doesn't, and tell advisors both. Your part is to say no when a client belongs on that second list. MAS's own example is a firm telling its advisors that a regular-premium investment-linked plan suited young executives building wealth, and did not suit anyone looking for pure protection.

Outcome 3 is where your week lives. Section 3.3.3 of the Guidelines describes a proper fact-find in four moves:

1. Ask enough to understand the client's financial needs and objectives.
2. Present enough options to fit their objectives, risk tolerance and circumstances, and weigh each product's features, liquidity, volatility and likely performance in good and bad markets.
3. Strongly encourage a client with limited product knowledge to take advice and finish the full fact-find.
4. Document the basis of recommendation: the client's objectives and needs, why this product, and what can go wrong.

Write the basis as if a stranger will read it, because one will. Your supervisor reads it in a sales review, compliance reads it in an audit, and an adjudicator reads it if the client disputes the sale. Three plain lines do it: what they told you they need, why this product meets that, and the risks you named. A thin basis starts with thin questions, so rehearse the needs questions in your sales process the night before the meeting.

Watch for the client who needs more care. The Guidelines name people with physical disabilities or impaired mental capacity, and the 2026 paper praised firms that drew the circle wider. For them, one of MAS's criteria for a selected client was enough, where MAS's definition needs two. A recent job loss counted. So did a death in the family, or signs that someone's physical or mental capability was slipping. Those firms offered a Trusted Individual and advised face to face. Before the transaction went through, a supervisor called the client back.

Language is the other flag. For a client who isn't comfortable in English, the Guidelines want an accurate translation of the documents and a supervisor or an English-speaking relative in the room. Then write down what you did to make sure they understood.

Outcome 4 wants the client to decide on plain words and the whole picture: features beside risks, and every cost on the table. That includes all fees and charges, the commission or other benefits you or your firm earn, and any free-look, lock-in or cooling-off period. Where returns or costs move, show the range of outcomes, the worst case included. Where the client can lose a large part or all of what they put in, say so first. On a health plan, go through the health declaration questions with them and tell them what happens to a claim if a condition goes undeclared.

Retire these four lines. The Guidelines name every one of them:

If a client still doesn't understand after you've explained it a second way, MAS's expectation is simple: don't proceed with the sale.

Timely means after the sale too. Clients should get updates on performance and on anything material, and a fee change gets clear notice, with a minimum of 30 days as the Guidelines' example. If a contract lets the provider revise its terms (a right of review clause), explain during the sale when it can be used, how much notice comes first, and what the client can do then.

The Guidelines also expect you to keep the periodic reviews you promise. Put the date on the client's record before you leave the meeting. In ActivityTracker's CRM that's one tap, In 3 months or In a year on the client's record, and the card's badge turns overdue if the day passes. Send the same-evening recap to the client's own chat, in their words, so the explanation exists in writing.

The Guidelines open outcome 5 with a plain line: every customer has the right to be heard. Firms need a system that documents, tracks and escalates complaints, with an assessment of each one on its merits. The Financial Advisers (Complaints Handling and Resolution) Regulations, which the Guidelines on Fair Dealing cite, require financial advisers to set up a unit that handles complaints, with a system that tracks and records them for at least five years.

The word that affects you most is independent. A complaint is assessed or reviewed by people who aren't connected to it or named in it. So you don't judge your own complaint. When one lands:

1. Write down the client's words, the date and the channel, the same day.
2. Hand it to your firm's complaints process that day. Don't argue the point and don't promise an outcome.
3. Tell the client who will contact them and by when. Your firm's own timeframes set that date.
4. Pull your file: the fact-find, the basis of recommendation and what you sent after the meeting.
5. When it closes, fix what the complaint exposed, from a script to a slide.

Your firm sets its own timeframes to acknowledge, interview and finish a review, and sends a written interim reply with an expected date when a complaint is complex. Clients should also know about FIDReC, ideally from onboarding. It's an independent dispute resolution centre for consumers and financial institutions, filing is free, and it adjudicates claims of up to S$150,000. Running a team? Decide now who takes a complaint when you're on leave and who it goes to next; the customer complaint escalation process walks a small team through it.

MAS is direct about pay. The Guidelines on Fair Dealing name product quotas and commissions that differ sharply between products as pay that leads to product pushing and improper switching. One good practice they describe paid a fixed salary plus a variable part, 40% of it on sales volume and 60% on client retention, assets under advice, complaints, compliance records, competency checks and client surveys.

You don't set your firm's pay plan. You do run your own pipeline review, and a campaign month changes the question you ask of it. MAS's poor practice is an advisor chasing a campaign target who sold a client the new, higher-paying product without comparing it with the alternatives. So for every deal on your list, ask: would the basis of recommendation read the same if every product paid the same? The same goes for switching: recommending a switch that earns you a fresh commission and costs the client new charges is out.

Outcome 3 puts specific duties on supervisors, and they fit in a weekly routine:

• Sit in on a new advisor's fact-finds and recommendations, and let them advise alone only once they've shown they can. That's MAS's good practice 3.1.
• Train the team on a new product's features and risks before anyone sells it, and say which clients it doesn't suit.
• Keep your span of control small enough to coach, and keep your own selling from crowding out supervision.
• Review a sample of sales: does the recommendation meet the client's needs, did a complex investment product sold to a client with limited knowledge get higher approval, and did the advisor follow the process?

In the 1:1, pick two files at random and read the basis of recommendation aloud together. The one-on-one meeting template has room for it next to the activity numbers.

Every outcome comes down to something you can show. Keep these on each client's record:

A spreadsheet works until a complaint arrives and you need one client's whole history in a hurry. Then it's slow. In ActivityTracker's CRM, the record's Activity tab lists notes, finished tasks and field changes day by day. If you offer clients a Trusted Individual, add a tick box for it once with New field, and it shows on every record.

Open your last five sales. For each, check that the needs are written in the client's words, that the basis of recommendation says why this product, and that the next review has a date. Fill the gaps while you still remember the meetings. Then add the missing line to your meeting checklist so the next client gets it the first time.

• Monetary Authority of Singapore, Guidelines on Fair Dealing, Board and Senior Management Responsibilities for Delivering Fair Dealing Outcomes to Customers, FSG-G04 (last revised 30 May 2024), read 28 October 2026
• Monetary Authority of Singapore, Guidelines on Fair Dealing [FSG-G04] page, read 28 October 2026
• Monetary Authority of Singapore, MAS Issues Guidelines on Fair Dealing (media release, 3 April 2009), read 28 October 2026
• Monetary Authority of Singapore, Information Paper on Good Practices of Market Conduct Controls in the Financial Advisory Industry (26 May 2026), read 28 October 2026
• Financial Industry Disputes Resolution Centre (FIDReC), home page, read 28 October 2026