Fictional scenario and findings · No real adviser or firm is assessed
MS-007 / Shopping mall roadshowShopper: 35-year-old salaried parent, low risk tolerance, seeking access to savings in two years. A long-term regular-premium endowment policy is recommended. The shopper declines to apply; no transaction is executed.
Review status: Two potential concerns for the firm to validate. Risk priorities below are illustrative ClearGauge assessments, not MAS ratings.
01 / Recommendation & suitability
REGULATORY CRITERIAFAA-N16 paragraph 11 covers client information collection and documentation. Paragraphs 28–31 address needs analysis, suitability—including tenor, risks, fees and liquidity—and explanation and documentation of the recommendation basis.
OBSERVED FACTSAt 14:10, the shopper explains that the savings are needed in two years. The representative asks about monthly income, but does not ask about liabilities, existing policies or regular financial commitments before recommending the long-term policy. The explanation focuses on projected maturity value without addressing the two-year need.
EVIDENCE & LIMITATIONSE01: notes completed immediately after the visit. E02: policy illustration supplied to the shopper. Internal eKYC/FNA and recommendation records have not been reviewed; absence from the conversation alone does not establish absence from the firm’s records.
POTENTIAL CUSTOMER IMPACTThe customer may commit funds needed earlier or exit with a loss. The observed recommendation rationale does not resolve the stated liquidity constraint.
VALIDATION & FOLLOW-UPThe firm should review the full fact-find, product terms and documented recommendation rationale, obtain the representative’s response, and assess whether a lapse occurred. If confirmed, provide targeted coaching and repeat the scenario after remediation. Proposed owner: practice standards / compliance; target: 10 working days, subject to client agreement.
02 / Roadshow prospecting & sales conduct
SUPERVISORY EXPECTATIONSFSG-G02 Safeguard 5 addresses unreasonable persistence and undue pressure. Safeguard 10 addresses gifts influencing purchase decisions. Safeguard 6 covers upfront representative and firm identity disclosure.
OBSERVED FACTSAfter the shopper twice says they want time to consider the recommendation, the representative repeats that an application is needed immediately to secure a promotional gift. The representative introduced their own name and firm upfront; identity disclosure is recorded as observed, separate from the pressure concern.
EVIDENCE & LIMITATIONSE01: contemporaneous visit notes and sequence of the shopper’s refusals. E03: promotional leaflet. The report does not infer the representative’s remuneration arrangements or whether the promotion had internal approval.
VALIDATION & FOLLOW-UPValidate the wording, context and promotion terms with the representative and event supervisor. If confirmed, amend the prospecting briefing and promotional script, then conduct a follow-up site visit or mystery shop. Proposed owner: roadshow supervisor / compliance; target: before the next event.
03 / Additional control checks
Recommendation documentsFAA-N16 paragraphs 35–37: recommendation record, client summary and applicable product documents. Internal records require a separately scoped review.
Selected-client safeguardsFAA-N16 paragraphs 10A–10D: classification and trusted-individual arrangements, where applicable. This persona does not test a selected-client scenario.
Transaction checksFAA-N16 paragraphs 41K onwards and FSG-G02 Safeguard 1: applicable transaction checks and roadshow follow-up. Not assessed: no application or purchase was made.
Roadshow oversightFSG-G02 Safeguard 2: mystery shopping and site visits. Programme coverage and event records require a separate review; one visit cannot establish firm-wide compliance.
Digital advertisingFSG-03 applies to digital advertising. If an online advertisement generates the lead, its content and customer journey can be included in the agreed scope. Not tested in this walk-in scenario.
How conclusions are reachedFindings distinguish notice requirements, guideline expectations and the firm’s own policy controls. Mark items observed, potential gap, not assessed or not applicable; request corroborating evidence before concluding a breach. No composite score overrides a significant finding.
MAS references used in this sample
Applicable requirements, exemptions and internal standards are confirmed when the programme is scoped. This sample illustrates reporting structure; it does not certify compliance.