Raymond Cheung
Chartered Actuary · CRO · Board Adviser · Singapore
MAS supervisory reviews have become more thematic, more substantive, and more consequential for leadership teams. Preparation is not about producing the right documents — it is about being able to demonstrate that governance is real rather than formal.
I have been on both sides of MAS supervisory interactions — as a CRO preparing for and managing regulatory reviews, and as an adviser helping boards and senior leadership teams understand what MAS is looking for and how to demonstrate it. The change I have seen over the last decade is significant. MAS reviews have become more thematic — focused on whether an institution's governance framework is actually operating as intended, not just whether it is documented. And the consequences of a poor review have become more serious.
The organisations that navigate MAS reviews well are not those with the thickest policy manuals. They are those where leadership can demonstrate, with evidence, that governance frameworks are producing real decisions — that risk appetite is influencing capital allocation, that board oversight is substantive rather than ceremonial, that the CRO function has genuine independence and the access it needs to do its job.
What MAS is actually looking for
From my experience, MAS supervisory reviews in the current environment are focusing on several themes consistently:
- Board oversight quality: are directors asking substantive questions, challenging management, and receiving information in governance terms? Or is the board meeting functioning primarily to ratify management decisions?
- Risk governance integration: is the risk framework connected to strategic and capital decisions, or operating as a separate compliance exercise?
- Climate risk management: under Notice 126 for insurers and equivalent guidance for banks, MAS is assessing whether environmental risk is embedded in financial risk governance — not just disclosed
- Operational resilience: how the institution would respond to a significant operational disruption, and whether the board has tested that response
- Model governance: for institutions using AI or algorithmic tools in underwriting, pricing, or credit decisions, the governance and validation of those models
“MAS is asking: does your governance work, or does it look like it works? The organisations that can answer honestly — and demonstrate the answer — navigate reviews well.”
How I help institutions prepare
My approach to MAS regulatory preparation is not about coaching for the review. It is about helping an institution assess honestly where its governance is genuinely strong and where it is more formal than substantive — and then addressing the gaps before MAS identifies them.
That typically involves a structured review of the risk governance framework against the specific MAS guidelines relevant to the institution type; an assessment of the board's risk information diet — what it is receiving, what it is not receiving, and whether the quality is sufficient for meaningful oversight; and preparation of leadership teams for the kinds of questions they should expect from a thematic review focused on the current MAS supervisory agenda.
The value of this preparation is not in passing the review. It is in building governance that is genuinely sound — which is what a well-functioning supervisory system is trying to verify.
Common Questions
What does MAS look for in a supervisory review of a Singapore insurer?
MAS assesses whether risk governance is genuine rather than formal — specifically whether the board exercises substantive oversight, whether the risk framework influences real decisions, and whether key areas including climate risk, model governance, and operational resilience are managed to the standard required by MAS guidelines.
How should a Singapore financial institution prepare for an MAS review?
Preparation should focus on honest gap assessment — identifying where governance frameworks are substantive and where they are more formal than real — and addressing structural gaps before the review. This includes reviewing the board's risk information quality, stress-testing whether key governance frameworks are producing evidence of real decisions, and ensuring leadership can articulate the governance framework clearly and with evidence.
About the author
Raymond Cheung is a Chartered Actuary, C-suite executive and board adviser with more than 20 years of experience across Asia in risk management, insurance, ESG and corporate governance. He is the CEO of CER Consultancy and an accredited trainer at SMU Academy and the Singapore College of Insurance.