Notice on Minimum Entry and Examination Requirements for Representatives of Holders of Capital Markets Services Licences and Exempt Financial Institutions (Updated May 2012) -- Part 2
16. If a company holds a CMS licence for fund management, would its employees who conduct activities such as client servicing, research, central dealing, business development and marketing be required to be appointed representatives and be required to pass the CMFAS Exam?
Generally, any employee who carries out activities that are necessary for, directly connected with or form an integral part of fund management, including the activities of portfolio management, research, client servicing and business development, will be required to be an appointed representative to conduct fund management. The employee will be required to pass the applicable Modules relevant to fund management (Module 3 and Module 6 or 6A), unless otherwise exempted.
If the company is also licensed for dealing in securities and/or trading in futures contracts for its central dealing activities, an employee who conducts central dealing will be required to notify as an appointed representative to conduct dealing in securities or trading in futures contracts, as may be applicable. Such employee is required to pass the applicable Modules relevant to dealing in securities or trading in futures contracts. An employee who also provides financial advisory services under the FAA such as marketing of collective investment schemes would be subject to the relevant examination requirements under the FAA.
17. For persons who do not have 4 GCE “O” level credit passes but have 3 years of relevant and continuous working experience in the regulated activities that they wish to conduct, would their 3 years of working experience qualify them for exemption from having to pass Module 6?
No. The exemption for persons who have 3 years of relevant working experience does not apply if such persons do not satisfy the minimum academic qualification i.e. 4 GCE “O” level credit passes.
18. Would a person who has taken some business and finance units as part of his degree or higher qualification programme be granted exemption from having to pass Module 6? More specifically, will his degree or higher qualification be accepted as having 'emphasis' on accountancy, actuarial science, business/business administration/business management/business studies, capital markets, commerce, economics, finance, financial engineering, financial planning, or computational finance as required in Annex 1 or Annex 1A of the Notice?
To qualify for exemption from Module 6, a major in the degree or higher qualification has to be in the areas mentioned above. Alternatively, a degree or higher qualification must have more than 50% of its syllabus in the areas mentioned above.
19. For persons who have passed Module 3, have been exempted from Modules 6 and 6A, and wish to join a start-up boutique fund manager to conduct fund management activities, do they have to take any other CMFAS exam?
No.
20. For persons who wish to be an appointed representative and have queries on how to seek exemptions from certain modules of the CMFAS Exam, whom should the person approach?
They should refer to the Notice on Minimum Entry and Examination Requirements for Representatives of Holders of Capital Markets Services Licence and Exempt Financial Institutions [Notice SFA 04-N09] for more details of available exemptions. As a proposed appointed representative must be supported by a principal, they should discuss with the principal supporting their appointment on whether any exemption would apply to them.
Generally, any employee who carries out activities that are necessary for, directly connected with or form an integral part of fund management, including the activities of portfolio management, research, client servicing and business development, will be required to be an appointed representative to conduct fund management. The employee will be required to pass the applicable Modules relevant to fund management (Module 3 and Module 6 or 6A), unless otherwise exempted.
If the company is also licensed for dealing in securities and/or trading in futures contracts for its central dealing activities, an employee who conducts central dealing will be required to notify as an appointed representative to conduct dealing in securities or trading in futures contracts, as may be applicable. Such employee is required to pass the applicable Modules relevant to dealing in securities or trading in futures contracts. An employee who also provides financial advisory services under the FAA such as marketing of collective investment schemes would be subject to the relevant examination requirements under the FAA.
17. For persons who do not have 4 GCE “O” level credit passes but have 3 years of relevant and continuous working experience in the regulated activities that they wish to conduct, would their 3 years of working experience qualify them for exemption from having to pass Module 6?
No. The exemption for persons who have 3 years of relevant working experience does not apply if such persons do not satisfy the minimum academic qualification i.e. 4 GCE “O” level credit passes.
18. Would a person who has taken some business and finance units as part of his degree or higher qualification programme be granted exemption from having to pass Module 6? More specifically, will his degree or higher qualification be accepted as having 'emphasis' on accountancy, actuarial science, business/business administration/business management/business studies, capital markets, commerce, economics, finance, financial engineering, financial planning, or computational finance as required in Annex 1 or Annex 1A of the Notice?
To qualify for exemption from Module 6, a major in the degree or higher qualification has to be in the areas mentioned above. Alternatively, a degree or higher qualification must have more than 50% of its syllabus in the areas mentioned above.
19. For persons who have passed Module 3, have been exempted from Modules 6 and 6A, and wish to join a start-up boutique fund manager to conduct fund management activities, do they have to take any other CMFAS exam?
No.
20. For persons who wish to be an appointed representative and have queries on how to seek exemptions from certain modules of the CMFAS Exam, whom should the person approach?
They should refer to the Notice on Minimum Entry and Examination Requirements for Representatives of Holders of Capital Markets Services Licence and Exempt Financial Institutions [Notice SFA 04-N09] for more details of available exemptions. As a proposed appointed representative must be supported by a principal, they should discuss with the principal supporting their appointment on whether any exemption would apply to them.
28. IBF has announced that from 1 January 2012, they will discontinue Module 7 of the CMFAS. Can persons who have passed Module 7 before 1 January 2012 still submit their notification to carry out trading in futures contracts or leveraged foreign exchange trading on and after 1 January 2012?
Yes. If they submit their notification before 1 January 2012, their notification will be considered. If they submit their application on or after 1 January 2012, they have to pass the relevant modules of the CMFAS Exam.
29. Will persons who currently possess a qualification listed in Annex 1A continue to qualify for exemption from Module 6 on and after 1 January 2012?
Yes. They will continue to be exempted from Module 6.
30. Will persons who currently possess a qualification listed in Annex 2A continue to qualify for exemption from Module 7 on and after 1 January 2012?
As Module 7 is discontinued and replaced with Module 6A on 1 January 2012, the exemption from Module 7 will only be applicable until 1 January 2012. They will be exempted from the requirement to pass Module 6A if they meet the criteria as set out in paragraph 18C of the Notice on Minimum Entry and Examination Requirements for Holders of Capital Markets Services Licence and Exempt Financial Institutions [Notice SFA04-N09].
Yes. If they submit their notification before 1 January 2012, their notification will be considered. If they submit their application on or after 1 January 2012, they have to pass the relevant modules of the CMFAS Exam.
29. Will persons who currently possess a qualification listed in Annex 1A continue to qualify for exemption from Module 6 on and after 1 January 2012?
Yes. They will continue to be exempted from Module 6.
30. Will persons who currently possess a qualification listed in Annex 2A continue to qualify for exemption from Module 7 on and after 1 January 2012?
As Module 7 is discontinued and replaced with Module 6A on 1 January 2012, the exemption from Module 7 will only be applicable until 1 January 2012. They will be exempted from the requirement to pass Module 6A if they meet the criteria as set out in paragraph 18C of the Notice on Minimum Entry and Examination Requirements for Holders of Capital Markets Services Licence and Exempt Financial Institutions [Notice SFA04-N09].
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