Our Response to the Latest MAS Consultation

2023-08-04  •  3 min read

Monetary Authority of Singapore (MAS)
10 Shenton Way
MAS Building
Singapore 079117

2 August 2023

Consultation on Proposed Amendments to the Payment Services Regulations 2019 (“PSR”), to implement key segregation and custody requirements for digital payment token (“DPT”) services under the Payment Services Act 2019 (“PS Act”). Consultation Paper: P007- July 2023

Dear Sir/Madam,

Ceffu SG Pte. Ltd. (“Ceffu”) welcomes the opportunity to respond to MAS’s consultation on proposed amendments to the Payment Services Regulations 2019 (“PSR”) and associated consequential amendments.

Ceffu provides custody services to institutional clients operating out of Singapore and intends to apply for a license with the Monetary Authority of Singapore when the relevant regulatory framework comes into force. Since launching our institutional services in 2021, Ceffu has devoted its operational and technological resources to growing a compliant and audited institutional-grade infrastructure that addresses the ever-growing needs of global clients, the likes of large financial services firms, institutional investors, and crypto-native firms.

Ceffu is keen to collaborate with policymakers and regulators globally and in Singapore to contribute to the development of a regulatory framework with consumer protection, market integrity and financial stability at its heart.

We hope you find our response to the consultation helpful and we look forward to discussing our response in further detail.

Thank you for taking the time to engage with us.

Yours faithfully, Ceffu

Responses as submitted via on-line link:

Question 1. MAS seeks comments on the general requirements for DPTSPs set out in paragraph 3.4 and for DPT Platform Operators set out in paragraph 3.5.

Overall, we welcome the proposed changes to the PS Regulations as we believe that the implementation of robust and forward-looking regulation will foster crypto adoption and ensure a stable and supportive environment for businesses operating in this space.

However, Ceffu believes that more consideration is needed concerning specific expectations or thresholds regarding the operation of crypto-assets holdings in “hot” and “cold” storage. We are of the opinion that the proportion and mix of Digital Payment Tokens (DPTs) in hot and cold wallets should be dependent on the DPT Service Provider's (DPTSP) business model and managed according to its liquidity risk management policy and processes to ensure good operational resilience. We suggest that this proportion and mix should be flexible and managed operationally by DPTSPs. For instance, mandating a small upper limit on the overall volume of DPTs that can be stored in a DPTSP's hot wallet (e.g., 10 %) could:

  1. (i) impact the speed at which customer withdrawals can take place; 

  2. (ii) compromise the security systems of the DPTSP as it will require more frequent sweeping from the cold to the hot wallet; and

  3. (iii) this approach may limit the operation of DPTSP's custody service offerings.

We understand that more detailed Guidelines will be provided later this year. In respect of implementation measures for the amended PS Regulations by DPTSPs we would request for MAS to ensure:

  • adequate time and opportunity for industry to engage on any binding guidance.

  • adequate transitional measures to allow firms time to interpret, adapt and comply with final rules and guidance.

  • consistency with respect to how global standard setting bodies approach the regulation and oversight of crypto-asset activities.