Recently we wrote an article on the license options provided in the Singapore Payment Services Act (PSA). At the end of 2019 before the PSA came into force the Monetary Authority of Singapore issued an important notice on disclosures that need to be communicated by payment institutions to their customers. The complete text of the notice is referenced below in this article.
Disclosure Statement by Standard Payment Institutions
Every entity that holds a standard payment institution license must provide the following statement for its customer and potential customers:
“ is licensed by the Monetary Authority of Singapore to provide
. Please note that this does not mean you will be able to recover all the money you paid to if ’s business fails.”
This statement must be shared with every customer as is prior to providing any kind of payment service to the customer. It must be provided in writing and should be published on the website of the payment institution. MAS has also included rules stating that the cited notice should not be embedded in other unrelated writing. It must be of a reasonable typeface and size which means that you can’t just type the statement in a small text somewhere at the bottom of the respective webpage together with a dozen other disclaimers.
Using the Disclosure Statement in Offers and Ads
If your company holds a standard payment institution license and wants and uses third-party advertising services you must make sure that the advertising company includes the statement as is in all offers and in any form of advertising.
Accurate Representation of the License Scope
When you communicate with your customers the fact that your company has been granted a standard payment institution license under the PSA you must always make sure that you don’t misrepresent the сcope of the license.
Special Rules for Digital Payment Token Service Providers
In addition to the disclosure statement, if your company offers services related to digital payment tokens, you must also provide a risk warning statement to all your customers. Here is the text of the statement that you need to include:
“The Monetary Authority of Singapore (MAS) requires us to provide this risk warning to you as a customer of a digital payment token (DPT) service provider.
Before you pay your DPT service provider any money or DPT, you should be aware of the following:
1. Your DPT service provider is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to your DPT service provider if your DPT service provider’s business fails.
2. You should not transact in the DPT if you are not familiar with this DPT. Transacting in DPTs may not be suitable for you if you are not familiar with the technology that DPT services are provided.
3. You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.“
The rules for the publishing of the text above are the same as the ones that apply to the disclosure statement for all licensees under the PSA. The only difference is that, given the length of the warning, you don’t have to include it when using third-party advertising services.