[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"doc-seo-280272-105":3,"detail-sidebar-cat-1-en-105":81,"doc-detail-280272-en":127},{"code":4,"msg":5,"data":6},0,"ok",{"site_id":7,"language":8,"slug":9,"title":10,"keywords":11,"description":12,"schema_data":13,"social_meta":74,"head_meta":76,"extra_data":78,"updated_unix":80},105,"en","preparing-your-license-application-questions-to-answer-thoughtfully","Preparing Your License Application - Questions to Answer Thoughtfully","","Practical guidance for payment service providers preparing a license application under Singapore’s Payment Services Act focuses on challenging parts of Form 1. The text analyzes Question 3.7 on the Letter of Responsibility, including how MAS describes the expected commitment and how to manage wording issues with parent or related entities. It also covers Question 7.8 on transaction or process flow diagrams, stressing consistency with the business plan and attention to roles of other parties. The guidance further discusses “possession” of intangible assets in regulated activity scope, and implications for major payment institution status thresholds.",{"@graph":14,"@context":73},[15,34,56],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/template/","Template",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/template/forms/","Forms",3,{"item":32,"name":10,"@type":21,"position":33},"https://docshare.wps.com/template/preparing-your-license-application-questions-to-answer-thoughtfully/280272/",4,{"url":32,"name":10,"@type":35,"image":36,"author":41,"headline":10,"publisher":44,"fileFormat":47,"inLanguage":8,"description":12,"dateModified":48,"datePublished":49,"encodingFormat":47,"isAccessibleForFree":50,"interactionStatistic":51},"DigitalDocument",{"url":37,"@type":38,"width":39,"height":40},"https://docshare.wps.com/thumbnails/preparing-your-license-application-questions-to-answer-thoughtfully/280272.png","ImageObject",442,249,{"name":42,"@type":43},"Eden","Person",{"url":19,"name":45,"@type":46},"DocShare","Organization","application/pdf","2026-10-30","2026-09-16",true,{"@type":52,"interactionType":53,"userInteractionCount":55},"InteractionCounter",{"@type":54},"ViewAction",8,{"@type":57,"mainEntity":58},"FAQPage",[59,65,69],{"name":60,"@type":61,"acceptedAnswer":62},"What is the purpose of the Letter of Responsibility in Form 1 Question 3.7?","Question",{"text":63,"@type":64},"It requires the PSP to provide a letter issued by a parent company or related entity accepting full responsibility for the applicant’s operations. The text notes MAS does not specify exact wording, but describes the concept as a commitment to maintain adequate oversight.","Answer",{"name":66,"@type":61,"acceptedAnswer":67},"How should a PSP approach Form 1 Question 7.8 about transaction or process flow?",{"text":68,"@type":64},"The PSP should attach diagrams describing the transaction end-to-end process, including any innovative technology and payment/settlement arrangements and fees. The diagrams should match the transactions described in the PSP’s business plan, including providing diagrams for multiple primary transaction types.",{"name":70,"@type":61,"acceptedAnswer":71},"Why is “possession” of money or digital payment tokens important for a regulated activity?",{"text":72,"@type":64},"For the regulated activity of facilitating the exchange of digital payment tokens, the PSP must “come into possession” of money or a digital payment token. The guidance highlights uncertainty around what possession means for intangible assets and explains that the PSP’s model could affect whether regulated activity occurs.","https://schema.org",{"og:url":32,"og:type":75,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":77,"canonical":32},"index,follow",{"doc_id":79,"site_id":7},280272,1790659329,{"code":4,"msg":82,"data":83},"success",[84,89,94,99,104,109,113,118,123],{"id":85,"doc_module":22,"doc_module_name":25,"category_name":86,"show_sort_weight":87,"slug":88},11,"Presentations",90,"presentations",{"id":90,"doc_module":22,"doc_module_name":25,"category_name":91,"show_sort_weight":92,"slug":93},12,"Resumes",80,"resumes",{"id":95,"doc_module":22,"doc_module_name":25,"category_name":96,"show_sort_weight":97,"slug":98},14,"Invoices",70,"invoices",{"id":100,"doc_module":22,"doc_module_name":25,"category_name":101,"show_sort_weight":102,"slug":103},15,"Posters",60,"posters",{"id":105,"doc_module":22,"doc_module_name":25,"category_name":106,"show_sort_weight":107,"slug":108},16,"Social Media",50,"social-media",{"id":110,"doc_module":22,"doc_module_name":25,"category_name":29,"show_sort_weight":111,"slug":112},17,40,"forms",{"id":114,"doc_module":22,"doc_module_name":25,"category_name":115,"show_sort_weight":116,"slug":117},18,"Letters",30,"letters",{"id":119,"doc_module":22,"doc_module_name":25,"category_name":120,"show_sort_weight":121,"slug":122},21,"Paper Templates",5,"papers-templates",{"id":124,"doc_module":22,"doc_module_name":25,"category_name":125,"show_sort_weight":4,"slug":126},158,"General","general-158",{"code":4,"msg":82,"data":128},{"doc_id":79,"user_id":129,"nickname":42,"user_avatar":130,"doc_module":22,"category_id":110,"category_name":29,"doc_title":10,"doc_description":12,"doc_content":131,"file_id":132,"file_url":133,"file_type":134,"file_size":135,"view_count":55,"is_deleted":4,"is_public":22,"is_downloadable":22,"audit_status":22,"page_count":30,"language":136,"language_code":8,"site_id":7,"html_lang":8,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":12,"update_tm":140,"read_time":22},1374391974468,"https://ap-avatar.wpscdn.com/davatar_29158cc5080c5b710cf443261637dec0","PRACTICAL COMPLIANCE AND THE PAYMENT SERVICES ACT:  \nPREPARING YOUR LICENSE APPLICATION – QUESTIONS TO ANSWER THOUGHTFULLY  \n8 JANUARY 2020 – HOLLAND & MARIE  \nMost of the relevant forms and guidelines for the Payment Services Act (the “PS Act”), including the main license application form (“Form 1”) 1 have now been published by the Monetary Authority of Singapore (the “MAS”). Over the coming weeks, we intend to publish a series of articles considering various practical issues relating to applying for a license under or complying with the PS Act.  \nINTRODUCTION  \nMany payment service providers (“PSPs”) are preparing to apply for a license under the PS Act. In this article, we will discuss some of the more challenging questions in Form 1 and flag particular issues PSPs should consider when answering.  \nFORM 1 – KEY QUESTIONS  \nQuestion 3.7 – Letter of Responsibility  \nQuestion 3.7 asks the PSP to provide a letter of responsibility issued by a parent company or a related entity (if any) accepting full responsibility for all the operations of the applicant. The MAS does not provide specifics as to the exact wording of the Letter of Responsibility required, whether in Form 1 orin the Guidelines on Licensing for Payment Service Providers (the “ PS Act Licensing Guidelines”) . However, in the Guidelines on Criteria for the Grant of a Capital Markets Services License (the “CMS Licensing Guidelines”), the letter of responsibility is described as “a commitment from the applicant's parent company that it will maintain adequate oversight over the applicant's operations, financial position, compliance with laws, management and other relevant issues.”2 We anticipate that the wording will be substantially similar to what is expected for capital markets license holders.  \nPrior to submitting Form 1 , we recommend that PSPs discuss with its parent or sister company (as applicable) its ability to provide this letter of responsibility and whether any particular wording will be problematic. In particular, we recommend that the parent and sister company look at any restrictive covenants contained in debt instruments or other agreements that may prevent them from issuing the Letter of Responsibility. If there are issues regarding this question, a PSP will want to highlight those issues in its initial application submission rather than later in the process.  \nQuestion 7.8 – Transaction or process flow  \nThis question asks the PSP to attach a diagram to describe the beginning to end of a typical transaction, including any use of innovative technology as well as a discussion of the arrangements for customers to pay for or settle the transaction, including the payment of fees to the applicant.  \nFirst, PSPs should consider their response to this question in light of Appendix 3 to the PS Act Licensing Guidelines. In Appendix 3, the MAS sets out the details of the PSP’s business that must be disclosed as part of the PSP’s business plan. Obviously, the PSP’s answer to Question 7.8 should track the description of the transactions described in the business plan. If a PSP discloses two primary transaction types that will be effected in the PSPs business, the PSP should provide diagrams for both transaction types in response to Question 7.8.  \nThe diagram and “possession” of intangible assets  \nKelvin Low, formerly an associate professor at Singapore Management University, has commented  \n1 See [https://www.mas.gov.sg/-/media/MAS/Sectors/Forms-and-Templates/Form-1---Application](https://www.mas.gov.sg/-/media/MAS/Sectors/Forms-and-Templates/Form-1---Application)for-a-Payment-Service-Provider-Licence. pdf  \n2 See Footnote 5 of the CMS Guidelines.  \nthat bitcoins “cannot be possessed”.3 Similarly, the UK Jurisdiction Task Force4 recently stated that under English and Welsh law “a cryptoasset cannot be possessed”.5  \nNotwithstanding the foregoing, under the PS Act to be licensed for the regulated activity of facilitating the exchange of digital payment tokens (","cbCaijsMoaKV91VR","https://ap.wps.com/l/cbCaijsMoaKV91VR","pdf",209380,"English","# Introduction\n# Form 1 - Key Questions\n## Question 3.7 - Letter of Responsibility\n## Question 7.8 - Transaction or process flow\n## The diagram and “possession” of intangible assets\n## Impact on your status as a major payment institution","[{\"question\":\"What is the purpose of the Letter of Responsibility in Form 1 Question 3.7?\",\"answer\":\"It requires the PSP to provide a letter issued by a parent company or related entity accepting full responsibility for the applicant’s operations. The text notes MAS does not specify exact wording, but describes the concept as a commitment to maintain adequate oversight.\"},{\"question\":\"How should a PSP approach Form 1 Question 7.8 about transaction or process flow?\",\"answer\":\"The PSP should attach diagrams describing the transaction end-to-end process, including any innovative technology and payment/settlement arrangements and fees. The diagrams should match the transactions described in the PSP’s business plan, including providing diagrams for multiple primary transaction types.\"},{\"question\":\"Why is “possession” of money or digital payment tokens important for a regulated activity?\",\"answer\":\"For the regulated activity of facilitating the exchange of digital payment tokens, the PSP must “come into possession” of money or a digital payment token. The guidance highlights uncertainty around what possession means for intangible assets and explains that the PSP’s model could affect whether regulated activity occurs.\"}]","Preparing Your License Application - Questions to Answer Thoughtfully | PDF",1789535900]