Madam Goh passed a Customer Account Review on 10 August 2022 and opened a listed Specified Investment Product trading account. She has not transacted a listed Specified Investment Product through that account since. On 15 September 2025 she calls to buy a structured warrant. What must the firm do?
MAS Notice SFA 04-N12 paragraph 16 with RES 1B section 2.5.1.4 and RES 2B section 6.6.4: after 3 years from the date of the review the customer may not transact unless the trading test is met or a new review is done. The one-year validity belongs to the Customer Knowledge Assessment, which covers unlisted SIPs. Takeaway: 3 years from the review, not from the account.
One year and the knowledge assessment belong to unlisted products.
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