Singapore, 23 June 2025… We refer to Mr Tan Suee Chieh’s three open letters addressed to the Monetary Authority of Singapore (MAS) and Chairman of MAS, Deputy Prime Minister and Minister for Trade and Industry Mr Gan Kim Yong, between August 2024 and April 2025, regarding the proposed transaction by Allianz Europe B.V. (“Allianz”) to acquire shares in Income Insurance Limited (“Income”) (“transaction”).

2. In his open letters published on 2 August 2024, 5 August 2024, and 28 April 2025, Mr Tan posed questions regarding MAS’ regulatory oversight over the transaction. The matters relating to MAS had been addressed at the Parliament Sitting on 14 October 2024, in then-Minister for Culture, Community and Youth and then-Second Minister for Law, Mr Edwin Tong’s Ministerial Statement. Further explanations were also provided in the speeches made by Minister Tong as well as Deputy Chairman of MAS, then-Minister for Transport, and then-Second Minister for Finance, Mr Chee Hong Tat as part of the Parliamentary debate on this matter on 14 and 16 October 2024. These are a matter of public record and are available in the Hansard.

3. On 9 June 2025, Mr Tan wrote to MAS, seeking a response to his 28 April 2025 open letter, as well as to request for a meeting with Chairman of MAS, Deputy Prime Minister and Minister for Trade and Industry Mr Gan Kim Yong, or a senior MAS representative.

4. In view of the above, MAS sets out below the relevant sequence of events and explains the key points.

MAS shared the capital reduction plan with the Ministry of Community, Culture and Youth (MCCY) while the proposed transaction was still subject to regulatory approval

5. On 17 July 2024, Allianz made a Pre-Conditional Voluntary Cash General Offer (“pre-conditional VGO”) to acquire at least 51% of the shares in Income, subject to regulatory approval. In order to make this pre-conditional VGO, Allianz and NTUC Enterprise (NE) had received approval from MAS under section 27(2) of the Insurance Act 1966.  This approval allowed NE and Allianz to enter into an agreement or arrangement to act together to acquire an interest of 5% or more of Income’s voting shares. The proposed transaction was subject to further regulatory approval from MAS for Allianz to obtain effective control and become a substantial shareholder of Income, under s26(1) and s27(1) of the Insurance Act 1966. MAS had reserved its rights to grant or refuse its approval under these 2 sections. 

6. At this point, the regulatory approval process was not completed and would have taken a few months for MAS to complete its assessment. Minister Chee explained at the 6 August 2024 Parliamentary Sitting that “the proposed deal was still subject to MAS' regulatory approval” and there was “due process for this”. On 16 October 2024, Minister Chee also said “there is no formal application yet by Allianz to obtain effective control and become a substantial shareholder of Income”.

7. In mid-July 2024, MAS had received Allianz’s preliminary business plan for Income. This included a set of business and financial projections, which included a plan for capital efficiency and reduction. There was no application to MAS to approve the capital reduction plan, neither did MAS give any such approval. Any capital reduction would need separate and specific MAS approval. Minister Chee explained in Parliament on 14 October 2024 that “At the time, MAS had reviewed the high-level submitted information based on prudential grounds, focusing on whether Allianz was fit and proper, looking at its financial strength and track record, and looking at the interests of Income’s policy-holders and ensuring that this will be safeguarded with a new strong substantial shareholder.” Minister Tong also explained that “MAS considered the planned capital optimisation from a prudential point of view, in accordance with its regulatory mandate” and that “MAS did not have reason for concern as Income was projected to continue to meet regulatory capital requirements with a healthy margin even with the capital reduction.”

8. After the 6 August 2024 Parliament Sitting, while MAS did not have prudential grounds for concern about the transaction, we noted that the planned capital reduction could be relevant to MCCY’s considerations taking into account Income’s prior status as a co-operative society. Minister Chee explained on 16 October 2024 that it was then that MAS surfaced this to the MAS Board and shared it with MCCY.  Before then, MAS had not been aware of the representations that Income had made to MCCY when it was allowed to carry over $2 billion in surplus to the new corporatised entity.

Government acted to stop the transaction.

9. After MAS had shared the information with MCCY, the Government decided to amend the Insurance Act and stop the transaction.

10. During the Parliament Sitting on 14 October 2024, Minister Tong explained that “When we first saw the announcements, we accepted the intent of the transaction, which is to strengthen Income.” He also stated that “The Government also does not have concerns over Allianz’s standing or suitability to acquire a majority stake in Income.”

11. However, MCCY found it “difficult to reconcile the proposed substantial capital reduction, soon after the transaction is completed, with Income’s representations to MCCY during the corporatisation exercise that it was aiming to build up capital resources and enhance its financial strength”. MCCY was also “not satisfied that Income will be able to continue fulfilling its social mission after the proposed transaction.”

12. On 16 October 2024, Parliament passed the Insurance (Amendment) Bill under a Certificate of Urgency so that there will be a clear statutory basis for MAS to consider MCCY’s views when approving or rejecting such applications. The Government also stated its view that the transaction in its then current form could not proceed.

13. On 16 December 2024, Allianz announced that it had withdrawn its pre-conditional VGO.

Additional resources and information

14. Further details on the above can be found in the following parliamentary replies and speeches linked below:

• 6 August 2024 Replies to Parliamentary Questions by Minister Chee Hong Tat
• 14 October 2024 Ministerial Statement by Minister Edwin Tong
• 16 October 2024 Insurance (Amendment) Bill – Second Reading Opening Speech by Minister Chee Hong Tat
• 16 October 2024 Insurance (Amendment) Bill – Response by Minister Edwin Tong during the Parliamentary debate
• 16 October 2024 Insurance (Amendment) Bill – Second Reading Closing Speech by Minister Chee Hong Tat

15. Given that the proposed transaction and amendments to the Insurance Act had been extensively debated in Parliament, and addressed again in this open reply, we have not acceded to Mr Tan’s request to meet with Chairman or senior representatives from MAS. Nevertheless, if Mr Tan has further feedback or information to share with us, we will duly consider them.