Identifying Reporting Obligations
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      Singapore: Who is a significant derivatives holder (SDH)? When does a person become an SDH?

      An SDH is a person who meets all of the following conditions:  

      1. he is not licensed by MAS (i.e. does not meet paragraphs (a) to (g) of the  definition of “specified person” in section 124 of the SFA);  
      2. he is a resident in Singapore; and 
      3. his aggregate gross notional amount of specified derivatives contracts which  are booked or traded in Singapore for the year exceeds $8 billion. 

      The aggregate gross notional amount for the year is to be assessed on the last day of  every quarter. 

      When a person meets all the conditions listed above, he – 

      1. is required to lodge with MAS a notification in Form 1A within 2 months  from the date on which he meets all the conditions; and  
      2. will be given 3 months (from the date on which he meets all the conditions)  to prepare to meet the reporting obligations. This means that at the end of  the 3-month period, he becomes an SDH and his reporting obligations  commences. 

      For example, if a person meets all the conditions on 31 March 2021, (i) he is required to  lodge Form 1A with MAS latest by 31 May 2021, (ii) he becomes a SDH on 1 July 2021, and  (iii) his reporting obligations as an SDH commence on 1 July 2021. 

      Form 1A is available on MAS website at this link. Please submit the soft copy of the  completed Form 1A via email to webmaster@mas.gov.sg, and attention the email to  Capital Markets Intermediaries Department III. 

      References:  

      • Section 124 of the SFA 
      • Regulation 6 of the SF(RDC)R