A representative wishes to sell a synthetic ETF to a retail client who has never dealt in derivatives. The correct first step is to:
A listed synthetic ETF is generally a Specified Investment Product, so a Customer Account Review (CAR) of the client's knowledge or experience in derivatives must be done before the client deals in it (MAS Notice SFA 04-N12, last revised 4 Jan 2019; FAA-N16, last updated 29 Dec 2025, for advisers). The Customer Knowledge Assessment is for unlisted SIPs. A client who does not meet the CAR is not barred. Extra safeguards apply instead: written notice of the outcome, the client's written confirmation, an explanation of derivatives risks or advice, and senior-management approval of the account.
Treating exchange listing as a waiver of the Customer Account Review, or wrongly barring retail clients entirely.
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