My post on LinkedIn can be seen here.

The Singapore bourse has for a number of years embraced the disclosure-based regime. Issuers and professional advisers have commented that a true disclosure-based regime must entail the market regulator eschewing a prescriptive approach within a disclosure-based regime – such as requiring how information in the prospectus and post-listing documents (like circulars to shareholders) should be disclosed or worded. Having a “hybrid” disclosure-based system with prescriptive requirements on how the prospectus and post-listing documents should be written does not sit well with the principles of a dynamic equities market. The proposed regulatory change will remove the anomaly and enhance the time to market for equity listings and proposed post-listing corporate actions. High standards can still be maintained by coming down hard on the errant persons who are responsible for making false, incomplete or late disclosures.

Placing non-performing Mainboard companies on the Watch List and allowing such companies that cannot get out of the list to “down-grade” to a Catalist listing may inadvertently create the impression that the Catalist market is a “scrap yard” for failing companies. The market regulator should set clear criteria to compulsorily delist non-performing Mainboard companies instead of keeping such companies on a “life-support machine”. The Singapore bourse should attract and retain sustainable and quality companies. Companies that are facing solvency issues or serious legal problems should be suspended and eventually de-listed. This will go a long way towards correcting the perception that the local bourse is a moribund market.

I support the recommendation to having a more targeted approach to post-listing queries, alerts and trading suspensions. The current practice of requiring issuers to publish their responses to queries from RegCo can create the unintended effect of disrupting the trading of an issuer’s shares. Directors of issuers who make false market announcements or tardy disclosures should be robustly taken to task. Investors should be given the ultimate right to make trading decisions without molly-coddling by the market regulators. This should be how a dynamic market functions.

I thank Ms Ranamita Chakraborty for publishing my views in the attached front-page story of the Singapore Business Times, 3 March 2025.

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