Who Needs CMFAS RES5? Licensing Path (2026)
"Do I actually need RES5?" has a written answer, and it is not a matter of opinion. The requirement sits in MAS Notice FAA-N26, the notice on competency requirements for representatives of financial advisers, issued on 28 September 2023 and in force since 1 April 2024. It names the activities that trigger the exam, the people who are carved out, and β the part almost nobody mentions β the point at which a RES5 pass stops being valid. This guide walks the notice in plain English. It is unofficial and not endorsed by MAS or SCI; the notice itself is linked at the end.
The rule in one paragraph
Under paragraph 4.3 of FAA-N26, before you can be an appointed representative for the financial advisory services listed in paragraph 4.1, you need two things: a valid pass in RES5, and a valid pass in the product knowledge module(s) matching the products you will advise on or arrange. RES5 is the common denominator β the product module is what changes from role to role. Both requirements flow from the Financial Advisers Act and FA Regulations, and passing is only step two: see how to become a financial adviser representative for the full path from exam to appointment.
Which activities trigger RES5?
Paragraph 4.1 lists them. You need RES5 if you will act as an appointed representative advising others β directly or in writing, print or electronic β concerning any of:
- securities
- units in a collective investment scheme
- exchange-traded derivatives contracts
- spot foreign exchange contracts for the purposes of leveraged foreign exchange trading
- over-the-counter derivatives contracts
- life policies
β¦or if you will be arranging any contract of insurance in respect of life policies (other than reinsurance). That second limb is the one most insurance and bancassurance recruits fall under.
Two carve-outs inside paragraph 4.1 itself
RES5 plus which product module?
Table 1 of FAA-N26 maps each activity to its product knowledge modules. For the financial advisory side β the SCI-administered modules most readers of this page will sit β it reduces to this:
| What you will advise on / arrange | RES module | Product knowledge modules |
|---|---|---|
| Life policies β advising, or arranging contracts of insurance | RES5 | M9 (excluded investment products) + M9A (specified investment products) |
| Units in a collective investment scheme | RES5 | M8 + M8A β but paragraphs 4.8β4.9 accept CM-EIP in place of M8 and CM-SIP in place of M8A |
| Securities | RES5 | CM-EIP + CM-SIP |
| Exchange-traded derivatives, leveraged FX, OTC derivatives | RES5 | CM-SIP (and CM-EIP for non-futures exchange-traded derivatives) |
Paragraph 4.4 then lets you sit one combined paper in lieu of the singles, which is what most new advisers actually do:
| Combined module | Replaces | You would take it if⦠|
|---|---|---|
| CM-LIP | M9 + M9A | You advise on or arrange life policies, including investment-linked ones |
| CM-CIS | M8 + M8A | You advise on collective investment schemes |
| CM-LIC | M8 + M8A + M9 + M9A | You do both β the usual tied-agency or bank wealth route |
| CM-CMP | CM-EIP + CM-SIP | Your products sit on the capital-markets (IBF) side |
Health insurance is a separate notice
Who does not need RES5
FAA-N26 sets out real exemptions, not vague ones. You are outside the RES5 requirement if any of these describes you:
| Situation | Where it comes from |
|---|---|
| Your advisory work is confined to research analyses/reports, or to spot FX other than for leveraged FX trading | Annex A, paragraph 1 |
| You advise only accredited investors, institutional investors, expert investors (capital markets products), related or connected corporations of your principal, or only on Government securities | Annex A, paragraph 2 (via paragraph 4.5) |
| You are an SFA appointed representative for dealing, your advice is limited to execution-related advice as a dealer, and you passed the matching RES module under MAS Notice SFA 04-N22 | Paragraph 4.7(a) |
| You are an SFA appointed representative for fund management advising only as a portfolio manager (or marketing rep of a Specified Fund Management Company) on products your firm manages, and passed the matching SFA RES module | Paragraph 4.7(b) |
| You passed the old Module 5, or completed SCI's non-examinable M5 course, under the cancelled FAA-N13 notice | Paragraph 4.11 β deemed pass, subject to the validity rules below |
Note what is not on that list: a degree, a CFA charter, or years of overseas experience. Those buy exemptions from certain product modules β Table B-1 of Annex B, for instance, exempts holders of a finance degree or the CFA from M8A and M9A β but there is no qualification-based exemption from RES5. If the activity catches you, you sit the paper.
The rule nobody tells you: a RES5 pass expires
This is the single most consequential paragraph in the notice for someone deciding when to sit. Under paragraph 4.15, a pass in RES5 ceases to be valid if you:
- did not commence providing financial advisory service as an appointed representative within three years of the date you passed; or
- ceased to provide it and did not re-commence as an appointed representative within three years of the date of cessation.
Paragraph 4.16 applies the same three-year clock to a deemed pass carried over from the old Module 5. And paragraph 4.19 is blunt about the consequence: where the pass ceases to be valid, you must re-take and pass RES5 to meet the requirement again.
A shorter clock if you rely on the academic exemption
What this means in practice
Before the exams: the entry requirements
Paragraph 3.1 sets two gates that apply regardless of which modules you need: you must be at least 21 years old, and hold a minimum academic qualification β GCE 'A' Levels with passes in three H2 and two H1 subjects, an International Baccalaureate Diploma, a Singapore polytechnic diploma, or an equivalent. Fitness and propriety under the MAS Guidelines (FSG-G01) applies on top. We unpack these in the financial adviser requirements guide.
The licensing path, start to finish
| Step | What it involves | Who does it |
|---|---|---|
| 1. Meet the entry requirements | Age 21+, minimum academic qualification, fit and proper | You |
| 2. Confirm your module set | RES5 + the product module(s) for your activities under FAA-N26 Table 1 (plus HI if relevant) | You + your appointing firm |
| 3. Pass the modules | Register with SCI for RES5 and the SCI product papers; IBF for the capital-markets ones | SCI / IBF |
| 4. Get appointed | Your principal lodges your appointment; you may act only once entered in the public Register of Representatives | Your firm β MAS |
| 5. Clock CPD every year | 6 core hours in ethics/rules and regulations (or a CPF Board course), plus supplementary hours by activity | You |
Two things worth internalising early. First, you cannot operate independently: you are appointed through a licensed financial adviser or an exempt financial adviser β banks and insurers exempt under section 20(1) of the FAA are squarely covered by FAA-N26 β so choosing your firm is a real decision. Second, the pass slip is not the licence; the Register of Representatives is. Both are covered in the financial advisory career path guide, along with the CPD hours in Part 5 of the notice.
So RES5 is the one gate that's entirely on you
Your firm handles the appointment. MAS maintains the register. Your age and diploma are already what they are. The exams are the only step whose outcome you control β and RES5 is the hardest of them, because it is the only CMFAS module with two pass hurdles in one sitting: 110 questions in Part I at 75% and 40 questions in Part II at 80%, both of which you must clear. See the exam format guide for the full breakdown and the registration guide for how to book a sitting.
The candidates who fail are rarely the ones who did not read enough β they are the ones who never self-tested under time, then met Part II questions that demand applying conduct and suitability rules to a messy client scenario rather than reciting a definition. Work through exam-style questions topic by topic, sit a free timed mock in the real format, and follow the plan in how to pass RES5.
How long does the whole path take?
The exams set the timeline. Confirming your module set takes a conversation with your firm; the appointment lodgement follows your passes. Most candidates spend several focused weeks on RES5 alone β size your runway here β and then a further stretch on the product paper. Given the three-year validity clock, the sensible order is: line up the firm, then sit the exams. Our complete RES5 preparation guide walks the whole journey from here.
Official sources
- MAS Notice FAA-N26 β competency requirements for representatives of financial advisers (paragraph 4.1 activities, Table 1 module map, paragraph 4.7 and Annex A exemptions, paragraphs 4.15β4.22 validity, Part 5 CPD)
- MAS Notice SFA 04-N22 β the capital-markets counterpart referenced by paragraph 4.7
- MAS Notice 117 β Training and Competency Requirement: Health Insurance
- SCI β Health Insurance (HI) examination details β the extra paper if your life policies carry accident and health benefits
- SCI β RES5 examination details β structure, question counts, pass marks and registration
Requirements change and only MAS and SCI speak authoritatively on your own situation β check both, and ask your appointing firm to confirm your module set in writing before you pay for anything. Create a free account and start practising RES5 today; the first 15 questions in every topic are free.
Frequently asked questions
Who needs to pass CMFAS RES5?
Paragraph 4.1 of MAS Notice FAA-N26 names the activities. You need RES5 to be an appointed representative advising others on securities, units in a collective investment scheme, exchange-traded derivatives, spot foreign exchange for leveraged foreign exchange trading, over-the-counter derivatives or life policies β or arranging any contract of insurance in respect of life policies. Advising by issuing research analyses or reports, and advising on corporate finance under the SFA, are carved out of that list.
Is RES5 enough to become a representative on its own?
No. Paragraph 4.3 of FAA-N26 requires a valid pass in RES5 plus a valid pass in the product knowledge modules matching what you will advise on β for example CM-LIP (in lieu of M9 and M9A) for life policies and investment-linked policies, CM-CIS (in lieu of M8 and M8A) for collective investment schemes, or CM-LIC for both. If your life policies carry accident and health benefits, MAS Notice 117 adds the Health Insurance module on top. Passing is also not the same as being licensed: your principal must lodge your appointment with MAS first.
Does a CMFAS RES5 pass expire?
Effectively, yes. Under paragraph 4.15 of FAA-N26 a RES5 pass ceases to be valid if you do not commence providing financial advisory service as an appointed representative within three years of passing, or if you cease and do not re-commence within three years of the date of cessation. Paragraph 4.19 then requires you to re-take and pass RES5. The window shortens to one year under paragraph 4.22 for someone relying on the pre-1 February 2014 exemption from the minimum academic qualification. Sit RES5 close to when you will actually be appointed, not years ahead.
Can a degree or CFA exempt me from RES5?
No. Qualification-based exemptions in FAA-N26 apply to product knowledge modules, not to RES5 β Annex B exempts holders of a finance, financial engineering or computational finance degree, or the CFA, from M8A and M9A, and there is a similar list for CM-SIP. There is no academic exemption from RES5 itself. The RES5 exemptions in paragraph 4.7 are narrow and activity-based, covering certain SFA dealing representatives giving execution-related advice and certain fund management representatives who passed the matching RES module under MAS Notice SFA 04-N22.
Go deeper: key CMFAS RES5 concepts
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