SINGAPORE Law and Practice Contributed by: Kenneth Pereire and Lin YingXin, KGP Legal LLC
3. Robo-Advisers 3.1 Requirement for Different Business Models In the context of robo-advisers, the question of whether distinct business models are required for different asset classes revolves around the unique characteristics and risk profiles associat - ed with each class. Asset classes, despite being often combined for diversification, frequently exhibit minimal or negative correlation. This prompts a consideration for tailored business models that align with the specific attributes of different asset classes. For example, “hold to collect” model may be well-suited for managing current assets like trade receivables, while “hold to collect and sell” approach may be more fitting for fixed assets such as bonds. 3.2 Legacy Players’ Implementation of Solutions Introduced by Robo-Advisers Robo-advisers first came to Singapore in 2018, with major banks like DBS, UOB and OCBC leading the way. By 2025, these banks have further expanded robo-advisory features, tar - geting less experienced individuals by offering accessible investment strategies and general financial advice. For example, DBS introduced DBS DigiPortfolio, which allows customers to invest in diversified portfolios managed by algorithms, seamlessly integrating this service with their traditional banking and wealth man - agement services. Similarly, OCBC RoboInvest offers automated portfolio management based on risk preferences, providing easy access to other financial products like loans and savings accounts. The integration process enables existing bank account holders to access the robo-adviser without the need for separate fund transfers, which typically take one to three working days.
This streamlined approach allows customers to invest instantly from their deposit accounts, blending traditional wealth management with modern fintech solutions. 3.3 Issues Relating to Best Execution of Customer Trades Best execution in the context of robo-advisers is a regulatory framework ensuring that financial service providers act in the best interest of their clients, optimising outcomes based on factors like price, cost and speed. However, there are challenges such as: • limited access to high-quality data; • rapid market changes during volatility; • technological risks, like system outages and cyber threats; • difficulty in analysing large volumes of data; and • lack of robust best execution policies. In Singapore, robo-advisers like DBS DigiPortfo - lio and OCBC RoboInvest must ensure favour - able execution for client trades, balancing auto - mation with the duty to achieve best prices. These platforms rely on algorithms, which must prioritise factors like price and cost, while adher - ing to the FAA. Technological risks and data volume also add complexity, requiring careful monitoring and transparency to meet regulatory standards.
4. Online Lenders 4.1 Differences in the Business or Regulation of Fiat Currency Loans Provided to Different Entities
In Singapore, a person who does not lend money to individuals or who lends solely to accredited investors will be an excluded moneylender under
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