Taking steps for disclosure regime to work in Singapore

WE operate a disclosure-based regime, but it is not a one-size-fits-all regime. The disclosure-based regime originated in the United States where the market dynamics are very different from Singapore's. They have a higher proportion of institutional investors in the market, more dispersed shareholdings and private enforcement is easier there because of class actions and lawyer contingency fees.

Many of these factors are absent or less developed in Singapore, where the market remains less litigious and driven by higher retail participation. Therefore, in order for the disclosure regime to work in Singapore, we have had to adjust. For example, because we don't have contingency fees and class action suits are more difficult, and we have more concentrated shareholdings compared to the US, we need to have stronger public enforcement in both disclosure and corporate governance.

Hence we issue public trading queries to listed companies when there is unusual trading in their shares, to tease out any undisclosed information that might explain the price or volume movements, and we may even warn the public of a prolonged false market through issuing what is known as a trade-with-caution announcement.