MAS Imposes a Composition Amount of $20,000 on Portfolio Builders (S) Pte Ltd, $7,500 on Martin Jeremy Gill, $7,500 on Richard James Hardy and $2,500 on John McNulty for Licensing Breaches under the Financial Advisers Act

1 Portfolio Builders (S) Pte Ltd ("PBS"), has paid a composition amount of $20,000 for contravention of section 13(1) of the Financial Advisers Act ("FAA"). Two of its consultants, Mr Martin Jeremy Gill ["Mr Gill"] and Mr Richard James Hardy ["Mr Hardy"], each paid a composition amount of $7,500 while one of its consultants, Mr John McNulty ["Mr McNulty"], paid a composition amount of $2,500 for contraventions of section 7(1) of the FAA.

2 PBS allowed its three representatives named above to conduct financial advisory services in Singapore without holding a valid financial adviser’s representative’s licence under the FAA, in breach of a condition of its financial adviser’s licence and hence, section 13(1) of the FAA.

3 Under Section 7(1) of the FAA, no person shall act as or hold himself out to be a representative of a licensed financial adviser unless that person holds a representative's licence related to that financial adviser. Mr Gill, Mr Hardy and Mr McNulty conducted financial advisory services without holding a representative's licence with PBS and hence contravened section 7(1) of the FAA.

4 The contraventions were uncovered by MAS during its inspection of PBS in February 2008.

5 Mr McNulty resigned from PBS as of 18 September 2007.


A Financial institution must ensure that any individual it appoints to provide financial advisory services holds the necessary licence.

MAS also expects CEOs to discharge the duties of their office properly.  This includes implementing effective policies and procedures to identify and address the risks associated with the business activities of the financial adviser and ensuring compliance with the relevant laws and rules.