2024-10-22

Added

MAS Notice 122 - Reporting Errors by Insurers

The Monetary Authority of Singapore issued this circular to address persistent reporting errors in MAS Notice 122 returns regarding asset and liability exposures. The regulator highlights specific inaccuracies such as incorrect Legal Entity Identifiers, wrong entity names, and mismatched location data, while also noting inconsistencies with Notice 129 submissions. Insurers are reminded of their legal obligation under the Insurance Act to exercise due care in providing accurate information and must implement proper systems to ensure regulatory compliance.

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ONFIDENTIAL Circular No: ID 15/24 22 October 2024 To Chief Executives All Licensed Insurers except for Captive Insurers and Marine Mutual Insurers Dear Sir/Madam MAS NOTICE 122 – REPORTING ERRORS BY INSURERS The enhancements to MAS Notice 122 (“Notice 122”) on Asset & Liability Exposures for Insurers were introduced on 1 January 2024. Part of the enhancements require insurers to submit detailed information that can uniquely identify an entity/ security. Examples include unique identifier of security, unique identifier of the deposit institution, name of issuer, Legal Entity Identifier (LEI) of issuer, location of issuer, and LEI of insurer’s ultimate parent. The Monetary Authority of Singapore (MAS) continued to observe reporting errors of such detailed information in the Notice 122 returns. Annex A lists out non-exhaustive examples of such reporting errors. 2 MAS also noted that some of the numbers reported in the Notice 122 returns were not consistent with the Notice 129 returns. MAS has provided further clarifications in the Glossary of Notice 122 at MAS website. Please refer to the track changes version in Annex B. 3 Section 142(1)(b) of the Insurance Act 1966 (“the Act”) provides that any person who provides the Authority with any information under or for the purposes of any other provision of the Act must use due care to secure that the document or information is not false in any material particular; and if the person does not use due care in this behalf and the document or information is false in a material particular, the person shall be guilty of an offence.

2 4 MAS takes a serious view of failures to comply with regulatory requirements, including inaccurate submission of information. MAS expects all insurers in Singapore to put in place proper systems and controls to ensure compliance with the applicable laws and regulatory requirements at all times. Yours faithfully [sent via MASNET] DANIEL WANG EXECUTIVE DIRECTOR INSURANCE DEPARTMENT

3 Annex A: Examples of reporting errors

  1. LEI was indicated as “NA” while there is LEI for the issuer/ Counterparty/ Deposit Institution/ Custodian. a. Insurers’ submission Name of Issuer/ Counterparty/ Deposit Institution/ Custodian LEI of Issuer/ Counterparty/ Deposit Institution/ Custodian Location of Issuer/ Counterparty/ Deposit Institution/ Custodian AERCAP IRELAND CAP/GLOBA NA IRELAND BLACKROCK, INC. NA UNITED STATES b. Correct information1
  2. Location information was wrong. a. Insurers’ submission Name of Issuer/ Counterparty/ Deposit Institution/ Custodian LEI of Issuer/ Counterparty/ Deposit Institution/ Custodian Location of Issuer / Counterparty/ Deposit Institution/ Custodian BLACKROCK INC 549300KXRVZGAAWQCG88 EUROPE BLACKROCK INC 549300LRIF3NWCU26A80 CAYMAN ISLANDS BLACKROCK INC 549300LRIF3NWCU26A80 UNITED KINGDOM BLACKROCK, INC 549300LRIF3NWCU26A80 IRELAND TENCENT HOLDINGS LTD 254900N4SLUMW4XUYY11 CHINA TENCENT HOLDINGS LTD 254900N4SLUMW4XUYY11 HONG KONG b. Correct information1
  3. Name was wrong or incomplete, or LEI was wrong, or location was wrong. a. Insurers’ submission Name of Issuer/ Counterparty/ Deposit Institution/ Custodian LEI of Issuer/ Counterparty/ Deposit Institution/ Custodian Location of Issuer / Counterparty/ Deposit Institution/ Custodian CITIBANK 5493008Z4LT56JZXGL54 SINGAPORE 1 https://search.gleif.org/#/search/

4 CITIBANK 549300U8H3KN0K301B23 UNITED KINGDOM CITIBANK 6SHGI4ZSSLCXXQSBB395 SINGAPORE CITIBANK E57ODZWZ7FF32TWEFA76 GUERNSEY CITIBANK E57ODZWZ7FF32TWEFA76 JERSEY CITIBANK E57ODZWZ7FF32TWEFA76 SINGAPORE CITIBANK E57ODZWZ7FF32TWEFA76 UNITED KINGDOM CITIBANK VGB4JDQHF6JTNV02DJ20 SINGAPORE CITIBANK WFLLPEPC7FZXENRZV188 SINGAPORE CITIBANK N.A. E57ODZWZ7FF32TWEFA76 SINGAPORE CITIBANK N.A. E57ODZWZ7FF32TWEFA76 UNITED STATES TEMASEK FINANCIAL I LTD 52990034RLKT0WSOAM90 SINGAPORE TEMASEK FINANCIAL I LTD 549300ZSV6VOGFH1ER70 SINGAPORE b. Correct information1

5 Annex B: Updated Glossary with Track Changes Glossary - Track Change.xlsx