The Answer in 60 Seconds Per MAS Notice FAA-N02, an "introducer" can introduce clients to a licensed financial adviser, share factual product information, and work from a script the financial adviser provides - but cannot give advice or recommendations on any investment product (a term that includes a life policy), or handle client money. The Notice is issued under section 58 of the Financial Advisers Act (Cap. 110). Covarage never recommends a product, and that is structural rather than a matter of policy.

The Sourced Detail

The legal framework

Per the MAS Notice FAA-N02 page, the Notice is issued under section 58 of the Financial Advisers Act (Cap. 110) and applies to all licensed financial advisers and exempt financial advisers. It governs the conduct of introducers - entities that introduce clients to a financial adviser without giving advice themselves.

The full title: "Notice on Appointment and Use of Introducers by Financial Advisers (FAA-N02)". Per the MAS page's amendment history, the Notice was first issued 1 October 2002, with amendments taking effect on 22 December 2003, 1 July 2005, and 26 November 2010.

Per the MAS Notice text PDF: "Under section 58(5) of the Act, any person who contravenes any requirement specified in written directions issued by the Authority (which includes this Notice), shall be guilty of an offence and shall be liable on conviction to a fine not exceeding $25,000 and, in the case of a continuing offence, to a further fine not exceeding $2,500 for every day or part thereof during which the offence continues after conviction." The Act was renumbered in its 2020 Revised Edition, in force from 31 December 2021: the power to issue written directions and the same penalty are now in section 67 of the Financial Advisers Act 2001.

What an introducer can do

Per regulation 31 of the Financial Advisers Regulations, FAA-N02 and the introducer disclosure published by KGI Securities, an introducer may:

  • Introduce a client to a licensed financial adviser
  • Provide factual information about the financial adviser
  • Share factual information on investment products, such as the product's name, its provider, its launch date, the minimum subscription and any fees or charges
  • Work from a script the financial adviser provides
  • Receive a remuneration or introducing fee from the financial adviser

What an introducer cannot do

Per the same standardised disclosure: the introducer when carrying out introducing activities is:

"(a) NOT permitted to provide you with any advice or financial advisory service or recommendations on any investment product, arrange any life insurance policies and other insurance-related products other than to the extent of carrying out introducing activities; (b) NOT permitted to receive or deal with any money or property from you in relation to this introducing activity; (c) NOT permitted to use any trade names, trademarks, intellectual properties in relation to [the financial adviser] nor distribute any advertising, promotional or marketing materials in relation to [the financial adviser]; and (d) NOT authorised to make any representation that the introducer is a representative or agent or enters into or conclude any transactions or contracts on behalf of [the financial adviser]."

This is the structural firewall. An introducer may not recommend any investment product, a term the Financial Advisers Act defines to include a life policy. Cannot say "this product is the right one for you." Cannot arrange the contract. Cannot hold client money. Cannot pretend to be the financial adviser.

Why this matters to SMEs evaluating insurance platforms

Three different arrangements can sit behind an "insurance platform" in Singapore:

  1. Direct insurer or insurer's tied agent. Sells a single insurer's products. Conflict-prone.
  2. Licensed financial adviser / insurance broker. Holds an FA licence under the FAA, or is registered as an insurance broker under the Insurance Act 1966; can recommend across insurers. Where the product is an investment product, which includes a life policy, the recommendation is regulated under FAA-N16 on Recommendations on Investment Products, needs analysis rules, and broader FAA conduct rules.
  3. Introducer under FAA-N02. Cannot recommend any investment product, a term that includes a life policy. Routes the customer to a licensed FA. Its role is to make the introduction, not to recommend a product. See how an introducer differs from a licensed FA or broker.

For an SME founder choosing where to source business insurance, the introducer model has a specific feature: the platform's role is to make the introduction, not to recommend a policy.

What MAS expects of an introducer-using financial adviser

Per the Notice itself, last revised on 26 November 2010, it imposes:

  • Disclosure obligations by introducers (declaring the relationship to the client)
  • Provision of script for use by introducers (the FA pre-approves the script)
  • Prohibition on handling client's money or property
  • Restriction on full-time / sole-business introducers : financial advisers should take reasonable steps not to appoint any introducer whose carrying out of introducing activities is, for a corporation, its sole business activity, or, for an individual, their full-time occupation

How Covarage is structured

Covarage (covarage.com) does not advise on, recommend or arrange insurance. Practically, this means:

  • Every page on Covarage, including this one, provides factual information with its sources, which include regulators such as MOM, BCA, SCDF and MAS and other bodies such as SCAL and CASE
  • Covarage does not name a "best" insurer for any line of cover. It cannot, structurally
  • Covarage does not handle premium money. Premiums flow directly between you and the insurer, via the licensed FA

This is what we mean by "recommendation firewall": it is not a brand promise.

What This Means for Your Business

Companies typically need to consider three things when evaluating any insurance platform:

  1. What licence is the platform operating under? Tied agent, licensed FA, introducer, or unlicensed?
  2. Can you verify it on MAS? Use the Financial Institutions Directory for the firm and the Register of Representatives for individuals
  3. Is the recommendation flowing from a structurally neutral source? A tied agent cannot recommend across insurers. An introducer cannot recommend any investment product, which includes a life policy. A licensed FA can - and is regulated when they do

Questions to Ask Your Adviser

  1. "Is your firm licensed as a financial adviser, an insurance broker, or operating as an introducer?"
  2. "What's your MAS Financial Institutions Directory entry, and what activities are you authorised to provide?"
  3. "Are you appointed under FAA-N02 by a financial adviser, and which one?"
  4. "How do you disclose your remuneration source to me - is it commission, fee, retainer?"
  5. "What's the script you operate under, and can I see it before we proceed?"

Related Information

Published 3 May 2026. Source verified 3 May 2026.