When an MP asked in February 2025 whether Singapore accredited investor status should depend on knowledge as well as wealth, the answer described a rule that rests on choice. In a written reply on 5 February 2025, MAS chairman Gan Kim Yong said the criteria were last updated in 2018. That update added a cap on the value of a client's home and a requirement that eligible investors "expressly opt in". A later change came on 4 October 2024, when MAS set a new method for valuing digital payment tokens. It asked firms to reassess affected clients by 4 July 2025.
Qualifying is therefore only half the matter. A client who passes the wealth tests keeps the full set of default protections until they opt in, after being told in writing which safeguards they give up. The adviser's file is what allows anyone, including a foreign offeror, to treat that client differently. That file should hold evidence for the test, the opt-in notice and consent, and a record of later checks, and it should be complete before any private US offering is discussed. The guide to US commercial real estate for advisors explains how such offerings are structured.
Who counts as a Singapore accredited investor
An individual can qualify in three ways under section 4A of the Securities and Futures Act. The first is net personal assets above S$2 million, about USD 1.57 million. Within that total, the net equity in the client's primary residence counts for no more than S$1 million, about USD 783,000. MAS has said the primary residence is the home where the client lives most of the time, in Singapore or abroad.
The second test is financial assets above S$1 million, net of related liabilities such as margin accounts and credit lines used to finance a portfolio. Mortgages and car loans are not deducted, because MAS does not treat property or cars as financial assets. The third is income of at least S$300,000, about USD 235,000, in the preceding 12 months. All US dollar figures here use the rate of 1.2776 Singapore dollars to the US dollar on 30 October 2026, from the Federal Reserve's H.10 release.
Digital payment tokens now count for less. Since 4 October 2024, under the MAS FAQs on the accredited investor definition, firms should apply a haircut of at least 50 per cent to their market value. The value that counts is capped at S$200,000, about USD 157,000. Firms should disclose the method and apply it fairly to all clients. India's version of the idea, set by SEBI, works differently, as the explainer on accredited investor rules in India shows.
How the accredited investor opt-in works
MAS designed the opt-in in its response to feedback of 22 September 2015. The firm gives the eligible client a written notice of the right to be treated as an accredited investor. The notice must clearly describe and warn of the safeguards that would stop applying. The client then confirms in writing that they wish to opt in and accept the reduced protection.
MAS expects the safeguards to be described in plain language and in practical terms, never as bare references to legal provisions. Opt-in papers should stay separate from account opening forms, although both may be handed over together. Confirmations may be electronic, and a verbal one is acceptable if the firm records it in writing and the client signs that record. The notice should also explain how to withdraw consent, and the firm processes a withdrawal within a reasonable period it sets.
Status is held firm by firm. A client may opt in with one firm and remain in the default category with another. Opting in with a private bank therefore does not by itself carry over to an independent adviser.
What the adviser's own licence changes
A licensed financial adviser deals with accredited investors under its licence. A smaller firm may instead rely on an exemption. The MAS FAQs on exempt persons, updated on 8 May 2025, cover the exempt financial adviser under regulation 27(1)(d) of the Financial Advisers Regulations. That exemption covers advice on investment products other than life policies to no more than 30 accredited investors on any occasion.
MAS states plainly that exempt persons are not licensed by it. It still expects them to do their own due diligence on each client's status, "supported by documentary evidence for proper audit trail". It also expects them to obtain and keep the opt-in and to monitor whether the client still meets the thresholds. For an exempt adviser, the client file is also the evidence that it works within its exemption.
Opting in does not end the duty of care. In the 2015 response, MAS called recommending products that match a client's risk preference "a basic duty" whatever the client's classification. The February 2025 reply added that the Fair Dealing Guidelines, updated in May 2024, expect firms to consider each customer's profile, risk tolerance and knowledge whatever their status.
The record an adviser keeps for a Singapore accredited investor
The first part is evidence. MAS expects independent documentary proof, and a client's self-declaration does not count. Assets held with other firms may be included only after reasonable checks on their amount. The firm should also collect enough information on liabilities to see which ones relate to financial assets. MAS's FAQs say firms remain "ultimately responsible" for confirming that a client meets the definition.
The second part is the opt-in itself. The record holds the notice as given to the client, the signed or recorded confirmation and its date, and the stated period for processing a withdrawal. Where the client's tokens were counted before 4 October 2024, it should also show the reassessment and the client's revised status.
The third part is the ongoing check. MAS expects firms to monitor whether clients still meet the tests and to remind them of their status and their right to opt out at any time. Opt-out requests should be properly documented. A later opt-out does not unwind what came before. Investments made while the client was an accredited investor are not affected, which matters for a private holding that may run for years.
Before a private US offering is discussed
The record often travels beyond the adviser's office. MAS's FAQs say an offeror can rely on the general opt-in obtained by the firm that manages the client relationship, without collecting a fresh one for each product. Where there is no separate account opening, MAS expects a fund manager to make sure the investor has opted in before accepting a subscription. A gap in the adviser's file can therefore become a gap in someone else's offer.
The advisory note should record which test the client meets and on what evidence. It should show the opt-in date, the next review date and why a private US holding suits this client's profile. It should also show that the risks were put plainly. Capital can be lost, property values can fall, tenants can leave and distributions may not be paid. Borrowing magnifies losses, the holding is illiquid and the Singapore dollar value moves with the exchange rate. One deal concentrates all of this in one property. Shares of a US corporation can also carry US estate tax for a Singapore resident, as the guide to US estate tax for global investors sets out.
Raveum is a US real estate platform, and interests in its deals are offered only to eligible investors outside the US under SEC Regulation S. Those investors invest through a US corporation, a blocker, that holds the property interest, and they typically receive Form 1042-S. Raveum lists no deal publicly and shows a Singapore investor no offering material until that investor's accredited investor opt-in is complete. Advisers can see how introductions work on Raveum's partner page.
The criteria have stood since 2018, and the tests are simple to state. The work lies in proving them and recording the client's choice, because MAS places that burden on the firm, not on the client. A Singapore accredited investor is, in practice, a client whose adviser can show the evidence, the notice, the consent and the last check. The guide to US commercial real estate for advisors covers what that client would be investing in.
Frequently Asked Questions
Who qualifies as an accredited investor in Singapore?
An individual qualifies with net personal assets above S$2 million, of which the primary residence counts for at most S$1 million. Financial assets above S$1 million net of related liabilities, or income of at least S$300,000 in the past 12 months, also qualify. Qualifying is not enough, because the client must also opt in.
How does the accredited investor opt-in work in Singapore?
The firm gives the eligible client a written notice explaining the right to opt in and the safeguards that would stop applying. The client confirms in writing that they wish to be treated as an accredited investor. Electronic confirmation is accepted, and a verbal one counts if recorded in writing and signed.
Does a primary residence count towards accredited investor status in Singapore?
Yes, but only partly. Under the net personal assets test, the net equity in a client's primary residence counts for no more than S$1 million of the S$2 million threshold. MAS defines the primary residence as the home where the client lives most of the time, whether it is in Singapore or abroad.
Can a client opt out of accredited investor status in Singapore?
Yes, at any time, and firms must remind clients of that right during periodic reviews. The firm processes the withdrawal within the reasonable period stated in its notice. Under MAS's FAQs, investments made while the client was an accredited investor are not affected by a later opt-out.
What is an exempt financial adviser in Singapore?
It is a person allowed to give financial advice without an MAS licence under a specific exemption. One exemption, regulation 27(1)(d) of the Financial Advisers Regulations, covers advice on investment products other than life policies to no more than 30 accredited investors on any occasion. Such advisers must still verify status and keep opt-in records.
What does a client give up by opting in as an accredited investor?
The client loses some of the protections the default category receives, such as the extra steps firms must take before selling complex products. The firm's duty to recommend only what suits the client's risk profile remains. The investment's own risks, including loss of capital, illiquidity and currency movements, are not reduced in any way.
This article is for general education and is not tax, legal or investment advice. Rules change and depend on individual circumstances. All investing involves risk, including loss of capital, illiquidity and currency movements. Offerings on Raveum are available to eligible investors only and are not open to the general public.
