Under SGX-ST Rule 8.9, when the Board declares a corner in a security, it is granted specific powers to restore market order and protect the public interest. A primary tool is to alter the settlement terms of outstanding contracts. The Board can mandate that these contracts be settled through a cash payment rather than the physical delivery of the cornered security. This action effectively breaks the manipulative power of the party holding the corner, as they can no longer dictate terms for physical delivery. To ensure impartiality, the fair settlement price used for this cash settlement is not determined by the Board itself, but by an independent Settlement Committee it forms. The Board then accepts the committee’s recommendation. The Board does not have the authority to unilaterally void past trades, determine the settlement price directly without a committee, or force the compulsory acquisition of shares from the cornering party as a primary remedy for declaring a corner.

Under the Securities and Futures (Licensing and Conduct of Business) Regulations (SFR (LCB)) and SGX-ST rules, a Trading Member is generally obligated to send monthly statements of account to all customers. However, an exception is provided for certain clients, including Accredited Investors. For a Trading Member to be exempt from sending monthly statements to an Accredited Investor, two specific conditions must be satisfied concurrently. Firstly, the firm must provide the client with access to their account information through real-time electronic statements. Secondly, the client must have explicitly requested, in writing, not to receive the monthly paper statements. A verbal request is insufficient, and simply having access to an online portal does not automatically waive the requirement without the client’s formal written instruction. The other options describe incorrect or incomplete procedures; for instance, sending only a quarterly statement is a separate requirement that applies if a monthly statement was not sent for the last month of a quarter, and is not an alternative to the opt-out process for an Accredited Investor.

This question assesses the ability to differentiate between Excluded Investment Products (EIPs) and Specified Investment Products (SIPs) based on the definitions in the SFA Notice on the Sale of Investment Products (SFA04-N12). EIPs are generally considered less complex and do not require a Customer Knowledge Assessment (CKA) before a transaction. The correct option describes units in a Singapore-listed Real Estate Investment Trust (REIT). According to Appendix D, units in a collective investment scheme that is a trust, invests primarily in real estate, and is listed on a securities exchange are classified as EIPs. The other options describe SIPs. A debenture backed by a portfolio of loans is an asset-backed security, which is explicitly not an EIP. A structured note, where returns are linked to an underlying asset’s performance, is also explicitly not an EIP. Lastly, a unit trust that engages in securities lending is not an EIP, as the rules for simple collective investment schemes to qualify as EIPs prohibit such activities.

Under the Securities and Futures Act (SFA), a Capital Markets Services (CMS) licence holder must seek prior approval from the Monetary Authority of Singapore (MAS) for the appointment of its chief executive officer or any of its directors. This is stipulated in Section 96 of the SFA. The primary purpose of this requirement is to ensure that the firm is managed by individuals who meet the ‘fit and proper’ criteria. A conviction for an offence involving dishonesty would almost certainly disqualify an individual from meeting these criteria. Therefore, the most critical and immediate issue is the severe governance breach of appointing an unapproved and non-compliant CEO. The firm’s obligation is to report this to MAS immediately and anticipate regulatory action, which includes the power for MAS to direct the removal of the officer. While addressing the internal control weakness (the faulty risk protocol) is also necessary, it is a consequence of the primary governance failure. Attempting to retroactively seek approval or delaying the report to MAS would be further breaches of regulatory obligations.

Under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA), a person commits an offence if they enter into an arrangement knowing or having reasonable grounds to believe that it facilitates the retention, control, or use of another person’s benefits from criminal conduct. In the scenario, the representative is not merely concealing funds but is actively creating a financial structure (the investment-backed loan arrangement) that allows the client to use the suspected illicit funds to acquire a legitimate asset (the property). This action directly falls under the offence of facilitating an arrangement for another person to retain or control their criminal benefits, as the arrangement makes the funds usable and integrated into the legitimate financial system for the client’s benefit. The other options are less precise. The representative is not laundering their own benefits, nor are they directly acquiring the illicit property for no consideration. While concealment is an element, the primary offence is the creation of the arrangement itself, which is a more specific and severe charge in this context.

The most significant indicator of a potential tax-related crime in this scenario is the client’s use of an external asset manager located in a jurisdiction known for inadequate regulation and supervision. This action is a classic red flag for tax evasion, as such arrangements are often used to obscure the beneficial ownership of assets and conceal them from tax authorities in the client’s home country. While frequent address changes are suspicious, they are a more general indicator and not specifically tied to tax crimes. Similarly, transferring funds from a country with capital controls points more directly to a potential breach of foreign exchange regulations rather than tax evasion itself. The stated purpose of ‘diversifying investments’ is vague but not inherently incriminating without further context. The use of a loosely regulated intermediary in a secretive jurisdiction is the most direct and compelling piece of evidence suggesting an intent to hide assets for tax purposes, as outlined in the MAS guidelines on suspicious transactions.

According to the principles outlined in MAS Notice SFA 04-N02 on Prevention of Money Laundering and Countering the Financing of Terrorism, a Capital Markets Services (CMS) licence holder retains the ultimate responsibility for conducting customer due diligence (CDD). This responsibility cannot be delegated to a third-party introducer, even if that introducer is regulated in a jurisdiction with standards equivalent to the Financial Action Task Force (FATF). Bearer shares pose a significant money laundering and terrorism financing risk because they obscure the identity of the ultimate beneficial owner (UBO), as ownership is determined by physical possession of the share certificate. Therefore, simply relying on an intermediary’s assurance or applying enhanced monitoring without first identifying the UBO is insufficient. The most appropriate and robust risk-mitigation strategy is to take concrete steps to identify the UBO and neutralize the risk associated with the bearer shares, for instance, by requiring their conversion to registered shares or having them held by a trusted custodian.

Under the Monetary Authority of Singapore (MAS) framework for preventing money laundering and terrorism financing, specifically outlined in notices such as MAS Notice SFA04-N02, a Capital Markets Services (CMS) licence holder retains the ultimate and non-delegable responsibility for conducting Customer Due Diligence (CDD). While an intermediary can introduce business, reliance on their due diligence does not absolve the CMS licence holder of its own obligations. This responsibility is heightened when dealing with high-risk structures like companies with ‘bearer shares,’ where the identity of the ultimate beneficial owner (UBO) is intentionally obscured. The primary regulatory expectation is for the firm to perform its own robust due diligence to pierce the corporate veil and ascertain the true identity of the UBO. Verifying the intermediary’s regulatory status is a preliminary step but does not permit the outsourcing of the core CDD obligation for a high-risk client. Similarly, while requiring the deposit of share certificates or applying enhanced monitoring are valid risk mitigation techniques, they are supplementary to, and not a replacement for, the fundamental requirement of identifying and verifying the client’s UBO at the outset of the relationship.

Under the Central Provident Fund Investment Scheme for the Ordinary Account (CPFIS-OA), members are subject to specific investment limits to ensure diversification and manage risk. The CPF Board stipulates that a member can invest up to 35% of their investable savings in shares, property funds (REITs), and corporate bonds. This 35% limit is a combined cap for all these instruments, not a separate limit for each. Separately, there is a distinct limit of 10% of investable savings for investments in gold products, which includes Gold ETFs. In this scenario, Mr. Chen’s investable savings are S$80,000. Therefore, the maximum combined amount he can allocate to shares and the property fund is 35% of S$80,000, which equals S$28,000. The maximum amount he can allocate to the Gold ETF is 10% of S$80,000, which is S$8,000. These two limits are independent of each other.

The primary concern in this scenario relates to potential market manipulation, specifically the practice known as ‘marking the close’. This involves executing transactions at or near the end of the trading day with the intention of influencing the security’s closing price. The client’s behavior exhibits several red flags outlined in market conduct rules. Firstly, the timing of the trades—consistently at the market close and at the end of a financial quarter—is suspicious. This timing is critical for valuation purposes, such as calculating a fund manager’s performance. Secondly, the client’s refusal to accept better prices earlier in the day strongly suggests that the primary motive is not to achieve the best execution price, but rather to establish a specific, artificial price at a key moment. This conduct is considered a breach of SGX-ST Rule 13.8.2(4) and Section 198 of the Securities and Futures Act (SFA), as it creates a false or misleading appearance with respect to the price of securities. The other options describe different forms of market misconduct. Pre-arranged trading involves colluding parties, which is not indicated here. Layering orders involves creating false market depth with orders that are not intended to be executed. Removing orders before execution (spoofing) involves placing non-bona fide orders to lure other traders. The described scenario fits the profile of price manipulation for valuation purposes most accurately.

Under the CPF Investment Scheme (CPFIS), a unit trust is eligible if it is managed by a Fund Management Company included under the scheme, has a sales charge not exceeding 3%, and maintains a Total Expense Ratio (TER) within the cap stipulated by the CPF Board. The described unit trust, with a 1.5% sales charge and a compliant TER, meets these requirements. In contrast, an endowment policy purchased with CPF funds must mature no later than the member’s 62nd birthday; a policy maturing at age 65 is ineligible. Furthermore, statutory board bonds offered exclusively to accredited investors under Section 275 of the Securities and Futures Act are not permitted for CPFIS investment, as these instruments must be generally available to retail investors. Lastly, for company shares to be eligible for CPFIS-OA, they must be listed on the SGX MainBoard, not the Catalist board.

This question assesses the understanding of the specific rules governing the handling of a remisier’s assets by an SGX-ST Trading Member, as outlined in SGX-ST Rule 12.12. According to SGX-ST Rule 12.12.6, a Trading Member is permitted to withdraw a remisier’s assets from a custody account under specific conditions, one of which is to use the assets to satisfy an amount that is due and payable by the remisier to the Trading Member. However, this action comes with a crucial subsequent obligation. SGX-ST Rule 12.12.6(v) explicitly requires the Trading Member to notify the remisier of this withdrawal by the next business day. The other options are incorrect because obtaining prior written consent is a requirement more aligned with lending or mortgaging a customer’s assets under the SFR(LCB), which does not apply to remisiers in this context. Transferring the assets to the Trading Member’s own account would constitute commingling, a practice strictly prohibited by SGX-ST Rule 12.12.5. While reporting to regulatory bodies is required for certain breaches, the primary and immediate obligation in this specific operational scenario is the notification to the remisier.

Under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA), specifically Section 37(1), financial institutions are required to retain Financial Transaction Documents (FTDs) for a minimum of five years after an account is closed. However, Section 38(1) and 38(2) address situations where an institution is legally required to release an original FTD before this period ends, such as in response to a court order. In such cases, the institution has a dual obligation: it must first make and retain a complete copy of the original document being released, and second, it must record the details of the release in a register. The copy must be kept until the original document is returned or until the initial five-year retention period concludes, whichever event occurs first. Simply logging the release without making a copy, refusing to comply based on the retention rule, or imposing an arbitrary return deadline are all incorrect interpretations of the specific procedures outlined in the CDSA for handling such legal requirements.

According to the MAS Notice SFA 04-N02 on Prevention of Money Laundering and Countering the Financing of Terrorism, a Capital Markets Services (CMS) licence holder may, in exceptional circumstances, establish business relations before completing identity verification if it is essential to avoid interrupting the normal course of business, such as for time-sensitive trades. However, this deferral is subject to strict timelines and risk management procedures. The regulations mandate that verification must be completed as soon as reasonably practicable and should not exceed 30 business days. If verification remains incomplete after 30 business days, the CMS licence holder is required to suspend business relations. This suspension involves refraining from carrying out any further transactions for the customer, with the potential exception of returning funds to their source. The relationship should only be terminated if verification is still not complete after 120 business days. Therefore, at the 35-business-day mark, the mandatory action is to suspend the account from further activity, not to terminate it or grant an extension.

The detailed explanation for this question revolves around the extra-territorial application of Singapore’s market conduct rules as stipulated in the Securities and Futures Act (SFA). The SFA is designed to protect the integrity of Singapore’s capital markets, and its provisions extend to actions committed outside Singapore if those actions would have constituted an offence if committed within Singapore. In this scenario, the trader’s actions in a foreign country directly and intentionally created a false or misleading appearance regarding the price of securities traded on the SGX-ST. This falls squarely under the market misconduct provisions. The key principle, as outlined in SFA Section 196, is that the location of the perpetrator is secondary to the location of the effect of their actions. Since the manipulative conduct had a direct and substantial impact on the Singapore market, the Monetary Authority of Singapore (MAS) has the jurisdiction to take enforcement action against the trader, regardless of their physical location or the location where the initial trades were placed. The other options are incorrect because they misinterpret the scope of the SFA. The Act’s jurisdiction is not strictly limited by geographical boundaries, nor does it solely hold the local intermediary responsible when the primary misconduct was orchestrated by a foreign entity. Furthermore, while international cooperation agreements are helpful for enforcement, the applicability of the SFA itself is not contingent upon their existence.

Under the MAS Notice on the Sale of Investment Products (SFA 04-N12), if a Capital Markets Services (CMS) licence holder or an exempt financial institution offers overseas-listed investment products but does not implement a system to identify and classify them as Excluded Investment Products (EIPs), these products must be treated as Specified Investment Products (SIPs) by default. Consequently, before allowing a retail customer to transact in such a product, the institution is required to conduct a Customer Account Review (CAR). The CAR assesses if the customer has the relevant knowledge or experience to understand the risks of SIPs. While providing a risk warning statement for overseas-listed products is also a requirement for the first transaction, the critical step triggered by the lack of a classification system is the CAR. A Customer Knowledge Assessment (CKA) is for unlisted SIPs, not listed securities. The institution is not prohibited from trading but must follow the prescribed procedure for SIPs.

According to SGX-ST Rule 8.7 concerning Direct Business, transactions that are not executed through the trading system but are dealt directly between parties (such as two customers of a Trading Member) are permissible if they meet certain criteria. These criteria include a minimum size of 50,000 units or a contract value of at least $150,000. The described transaction of 100,000 shares valued at $200,000 clearly meets these conditions. The rules further stipulate specific reporting timelines. For direct business executed after trading hours, the Trading Member is obligated to report the transaction through the married trade reporting system within the first 20 minutes of the Opening Routine on the subsequent market day. The option to report within 10 minutes applies only to trades executed during trading hours. Such trades must be reported and are not exempt, nor should they be broken down and entered into the regular order book.

Under the Securities and Futures Act (SFA), an auditor of a Capital Markets Services (CMS) licence holder has a statutory duty to report certain findings directly to the Monetary Authority of Singapore (MAS). Specifically, Section 107 of the SFA and the related guidelines require an auditor to immediately send a written report to MAS upon discovering any matter that adversely affects, or may adversely affect, the financial position of the licence holder to a material extent. The scenario describes a valuation practice that could materially misrepresent the firm’s financial stability, which falls squarely under this reporting requirement. The auditor’s primary obligation is not to seek internal resolution first, nor to contact customers directly, but to inform the regulator to enable swift oversight and intervention. If the CMS licence holder is a member of a securities exchange, a copy of the report must also be sent to that exchange. The other options describe actions that are either secondary or incorrect in this specific regulatory context.

According to MAS Notice SFA04-N02, a Capital Markets Services (CMS) licence holder is required to conduct an enterprise-wide risk assessment (EWRA) to identify and assess its Money Laundering and Terrorism Financing (ML/TF) risks. This assessment must be reviewed at least once every two years or when a material trigger event occurs, whichever is earlier. The acquisition of a new business line or customer segment, particularly one that introduces exposure to high-risk jurisdictions, is explicitly considered a material trigger event. Therefore, the firm’s primary and most critical obligation is to conduct a new EWRA to understand and recalibrate its risk framework and control measures to address the newly introduced risks. Simply waiting for the next scheduled review would be a regulatory breach. While implementing specific controls like dual control or conducting staff training are important subsequent actions, they must be informed by the findings of the updated risk assessment. Filing Suspicious Transaction Reports (STRs) is incorrect as it requires a specific suspicion related to a transaction or activity, not just the inherent risk profile of a client group.

Under the Securities and Futures (Licensing and Conduct of Business) Regulations, specifically Section 46, any advertisement that refers to past investment recommendations must adhere to strict transparency requirements to avoid misleading the public. If a firm chooses to highlight its past performance, it cannot be selective. The regulation mandates the inclusion of a comprehensive list of ALL recommendations, encompassing both profitable and unprofitable ones, made within at least the 12 months immediately preceding the advertisement’s publication. Furthermore, this list must be detailed, and the advertisement must feature a prominent statement clarifying that historical results are not indicative of future performance. The other options are incorrect because claims about analytical tools are permissible as long as their limitations are clearly disclosed, not necessarily removed. An offer described as ‘free’ must be genuinely unconditional; making it contingent on opening an account and trading violates this principle. Lastly, while a Trading Member must ensure its advertisements are compliant and do not bring the exchange into disrepute as per SGX-ST Rule 12.19, there is no general requirement to seek prior approval from SGX-ST for every market letter.

The explanation for the correct answer is rooted in the definition of ‘tipping-off’ under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA). Tipping-off occurs when a person knows or has reasonable grounds to suspect that an investigation is being or is about to be conducted, and they disclose information that is likely to prejudice that investigation. In this scenario, the manager’s statement, which mentions an impending ‘internal audit’ to discourage the filing of a Suspicious Transaction Report (STR), constitutes such a disclosure. The manager is attempting to prevent the STR, which would likely trigger an official investigation by an authorised officer. This action is specifically designed to prejudice the potential investigation. While the action is also a severe breach of the firm’s internal policies, its primary classification under Singaporean law is the criminal offence of tipping-off. ‘Failure to report a suspicious transaction’ would be the offence committed by the compliance officer if they were to heed the manager’s warning and not file the STR. ‘Aiding and abetting money laundering’ is a different offence that would require more direct involvement in facilitating the illicit transactions themselves, rather than just interfering with the reporting process.

The most appropriate and standard initial action by SGX-ST in response to unexplained, unusual trading activity is to issue a public query to the listed company. The primary purpose of this query is to determine if there is any material, non-public information that could be causing the trading anomaly and to compel the company to disclose it. This action serves to ensure the market remains informed. If, after the query, the company responds that it is unaware of any reason for the activity, SGX-ST would then typically issue a ‘Trade with Caution’ announcement. Suspending trading is a more severe measure, generally reserved for situations where the market is demonstrably disorderly or unfair, or if a company fails to respond adequately to a query. Declaring a security as ‘Designated’ is an exceptional and powerful tool used in cases of suspected market manipulation or excessive speculation, which involves imposing strict trading conditions like mandatory margins, and is not a first-line response to unusual activity.

According to SGX-ST Rule 8.7 concerning Direct Business, transactions that are not executed through the exchange’s trading system but meet certain criteria (known as married trades) have specific reporting obligations. For a direct business transaction executed after trading hours, the rule stipulates that the Trading Member must report it through the married trade reporting system during the first 20 minutes of the Opening Routine on the subsequent market day. The transaction in the scenario, with a contract value of $200,000, clearly exceeds the minimum threshold of $150,000, thus qualifying as a direct business transaction. The 10-minute reporting window applies only to direct business conducted during trading hours. The notion that such trades do not require reporting is incorrect, as all direct business must be reported to the exchange to ensure market transparency and integrity. Reporting before the pre-opening session is also incorrect as the rule specifies the reporting window is within the first 20 minutes of the Opening Routine.

This question assesses the understanding of the rules governing the mortgage of a customer’s assets by a Capital Markets Services (CMS) licence holder, as stipulated in the Securities and Futures (Licensing and Conduct of Business) Regulations, specifically Section 34. The core principle is that a CMS licence holder can only mortgage, charge, pledge, or hypothecate a customer’s assets for a sum not exceeding the amount owed by that customer. The regulation acknowledges that operational situations, such as a customer making a payment, can lead to a temporary excess where the pledged amount is greater than the outstanding debt. In such a case, the regulation does not consider it a contravention if the holder acts to rectify the situation promptly. The specific requirement is that the holder must reduce the excess as soon as practicable, with a final deadline of the next business day after the excess occurs. The other options are incorrect because the obligation to act is on the firm, not dependent on the client’s request. Holding the excess as a buffer is prohibited, and there is no requirement to report such a temporary operational adjustment to the Monetary Authority of Singapore.

Under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA), a person has two key obligations in this situation. Firstly, under Section 39, there is a duty to disclose knowledge or suspicion of illicit funds to an STR Officer. The representative has correctly initiated this process. Secondly, Section 48 of the CDSA makes it an offence to ‘tip-off’ another person. Tipping-off occurs when someone discloses information that is likely to prejudice an investigation, knowing or having reasonable grounds to suspect that an investigation is being or will be conducted. Informing the client about the suspicion, the internal report, or even a non-standard ‘compliance check’ could alert them and prejudice the investigation. Therefore, the representative must avoid any such disclosure. Executing the transaction despite having reasonable suspicion could constitute a money laundering offence under Sections 46 or 47 of the CDSA (assisting in converting or acquiring property representing benefits from criminal conduct). While the client’s inquiry is relevant, the primary duty is to follow the established STR process internally and not communicate anything that could compromise a potential investigation.

Under the Securities and Futures (Licensing and Conduct of Business) Regulations, specifically Section 46, any advertisement that refers to past recommendations must adhere to strict conditions to avoid being misleading. It is not sufficient to only highlight successful picks. The regulation mandates that if any past recommendation is mentioned, the advertisement must include a list of ALL recommendations, both profitable and unprofitable, made within at least the preceding 12 months. This list must be detailed, including the instrument’s name, date of recommendation, price at that time, and current price. Furthermore, any claim about a chart, formula, or device used for making investment decisions must be accompanied by a prominent disclosure of its limitations and the difficulties in its use. Lastly, if a service is advertised as ‘free’, it must be provided in its entirety without any conditions or obligations attached. Therefore, the firm must fulfill all these requirements to be compliant.

This question assesses the understanding of the Personal Data Protection Act (PDPA) and its Do Not Call (DNC) Registry provisions, as well as the SGX-ST rules on client information confidentiality. According to the PDPA, an organisation must not send a specified marketing message to a Singapore telephone number listed on the DNC Registry unless it has received clear and unambiguous consent from the user or subscriber of that number. The outsourcing of a function like risk management to a third-party vendor is permissible under SGX-ST Rule 12.2. However, this rule explicitly states that the Trading Member must ensure the party to whom information is disclosed maintains the confidentiality of that information. Furthermore, the disclosure is permitted for the necessary operations and risk management of the Trading Member, not for the vendor’s own marketing purposes. Therefore, even though the vendor has legitimate access to the client data for risk analysis, it cannot use this data for a secondary purpose like marketing without the client’s explicit consent, especially when the client is on the DNC Registry. The other options are incorrect because the existence of an outsourcing agreement for one function does not grant the vendor rights for other activities like marketing, and the primary responsibility for PDPA compliance remains with the Trading Member who collected the data.

The detailed explanation for this scenario is rooted in the regulatory hierarchy established by the Securities and Futures Act (SFA). The SFA grants the Monetary Authority of Singapore (MAS) ultimate oversight over approved exchanges like the Singapore Exchange (SGX). While SGX operates as the frontline regulator responsible for the day-to-day administration of the market and the formulation of its rules, this function is performed under the supervision of MAS. As the statutory regulator, MAS has the explicit power to review and approve any amendments to the rules of an exchange. This ensures that while the exchange can adapt to market needs, its rules remain aligned with the broader objectives of maintaining market integrity, investor protection, and financial stability, which are MAS’s key responsibilities. Therefore, SGX’s proposals are not final until they receive MAS’s approval. The other options are incorrect because they misrepresent this power structure. SGX’s board does not have the final say independent of MAS. A joint committee or consensus is not the mandated decision-making process, as the statutory power lies with MAS alone. Finally, while SGX’s risk-based approach is a guiding principle for its own operations, it does not override the legal requirement for MAS approval.

The situation described is a clear instance of unauthorised trading. According to SGX-ST Rule 13.6, a Trading Representative is strictly prohibited from using a customer’s account to conduct trades for a third party without obtaining the customer’s prior written authorisation. In this scenario, the representative used an inactive client’s account to execute a trade for his friend, which directly contravenes this rule. The client’s absence and the account’s dormant status do not mitigate the violation. Churning involves executing an excessive number of trades to generate commissions, which is not the primary issue here. Insider trading would involve trading on non-public, price-sensitive information, which is not mentioned in the scenario. Securities hawking relates to the unsolicited offering of securities to a person, which is different from executing an unauthorised trade in an existing client’s account.

According to SGX-ST Rule 12.7 and the Securities and Futures (Licensing and Conduct of Business) Regulations (SFR (LCB)), a Trading Member is generally required to send monthly statements of account to its customers. However, an exception exists for clients who are Accredited Investors. A Trading Member is not required to send a monthly statement to an Accredited Investor if two specific conditions are met concurrently: first, real-time electronic statements have been made available to the customer, and second, the customer has explicitly requested, in writing, not to receive such monthly statements. In the described scenario, while the firm has provided real-time electronic access, it only obtained verbal consent from the client. Documenting this verbal consent internally does not satisfy the regulatory requirement for a written request from the customer. Therefore, the firm’s action to cease sending statements is non-compliant.