| Contravention | Description |
| Acted through sub-agents who acted as referrers |
The agent involved referrers or persons who are not ARB-registered agents for the agent’s insurer, and these referrers or sub-agents conducted regulated activities such as advising or arranging insurance contracts or collecting insurance premiums. The agent paid referrers or sub-agents a share of the commission. |
| Acted for more than 3 principals |
The agent represented or acted for more than 3 principals by carrying out regulated activities such as arranging, advising, or earning commission or referral fees, either directly or as the controller of an entity. |
|
Cash agent acted as credit agent when collecting premiums |
As a cash agent, the agent collected premiums in its own name, whereas the premiums should have been paid directly to its principals. |
|
Did not pay outstanding Premiums |
The agent continued to owe outstanding premiums to its Principals beyond the credit period. |
|
Sub Agency |
The agent entered into an arrangement for the engagement of a sub-agent, where the sub-agent advised and arranged the insurance policies of the Agent's Principal and collected the insurance premiums. |
|
Cash - Agent Premium Payments was not made directly to the insurer |
The premiums were paid through the sub-agent whereas the premium should have been paid from the customer directly to his principal. |
|
Delegated functions and duties to another agent who was not the Nominee Agent |
The agent delegated his functions and duties as an agent to another agent, who was not his own nominee agent. |
|
Engaged in general insurance selling and advisory activities for a member which his corporate agency does not represent |
The agent advised on and arranged insurance policies for an insurer that his agency does not represent. |
| Compliance with the Audit | The agent did not fulfill the requirements of the audit conducted by the Board, such as providing reasonable cooperation and information necessary for the audit. |
| Accounts and Financial Aspects |
The agent did not maintain proper accounting records of transactions entered with policyholders and principals. |
|
Did not ensure as far as possible that the policy proposed is suitable to the needs and resources of the prospective policyholder. |
The agent did not explain the policy contract and application forms to the policyholder. |
|
Did not explain all essential provisions of the cover afforded by the policy or policies which he is recommending so as to ensure as far as possible that a prospective policyholder understands what he is or may be buying. |
The agent did not explain the policy contract and application forms to the policyholder |
|
Did not ensure that the consequences of non-disclosure and inaccuracies are pointed out to a prospective policyholder |
The agent did not explain the policy contract and application forms to the policyholder. |
| Staff member of corporate agent holding himself out as entitled to arrange a contract of insurance for an insurer the corporate agent did not represent. |
A staff member of a corporate agent: |
1. PK Consultancy and Management Pte. Ltd (C005320) - Published on 11 May 2021
The ARB found that PK Consultancy and Management Pte. Ltd. did contravene GIARR 4.1b(iii) (2020 version) in that it breached the credit period for outstanding premiums and owed outstanding premium to its principal.
The Agents' Registration Board ordered:
PK Consultancy and Management Pte. Ltd.’s registration with ARB to be cancelled with effect from 11 May 2021.
2. Assure Insurance Agency Pte. Ltd. (C004322) - Published on 18 May 2021
The ARB found that Assure Insurance Agency Pte. Ltd did contravene GIARR 4(ii) (2015 version) in that it received premiums in its own name even though it must not do this as a cash agent.
The Agents' Registration Board ordered:
Assure Insurance Agency Pte. Ltd. to be reprimanded pursuant to GIARR 14.4(c).
3. Credencel Insurance Agency (C005537) - Published on 18 May 2021
The ARB found that Credencel Insurance Agency did contravene GIARR 4(ii) (2015 version) in that it received premiums in its own name even though it must not do this as cash agent. The agent did not pay the premiums they received without deduction, claims or set-off whatsoever to their Principals.
The Agents' Registration Board ordered:
Credencel Insurance Agency to be reprimanded pursuant to GIARR 14.4(c).
4. DI Insurance Agency (C001439) - Published on 18 May 2021
The ARB found that DI Insurance Agency did contravene GIARR Appendix D (Code of Practice) 19, GIARR 4(ii), GIARR 10 and GIARR 4(iii)(b) and (c) (2015 version) in that it:
a. involved referrers or persons who were not ARB-registered agents for that insurer. In some cases, the premium was collected by the third party even though it did not represent the insurer as an agent.
b. infringed the 3 principal rule by taking part in placements and servicing of policies of insurers that are not its 3 principals, and earned referral fees from those policies from other agents.
c. infringed the cash agent regulations for the collection of premiums. As a cash agent, premiums were collected by this agent in the agent’s own name, instead of being paid directly to its principals. The agent did not pay the premiums it received without deduction, claims or set-off whatsoever to its Principals.
The Agents' Registration Board ordered:
DI Insurance Agency to be suspended for 6 months with effect from 13 April 2021 to 12 October 2021, during which it must not solicit general insurance business or engage in general insurance selling or advisory activities for any new clients. D I Insurance Agency is solely permitted to engage in general insurance selling or advisory activities for policy renewals of its existing clients. On appeal, the appeal committee appointed by the Management Committee affirmed the decision of the ARB.
5. Sincl Pte. Ltd. (C004895) - Published on 18 May 2021
The ARB found that Sincl Pte. Ltd did contravene GIARR 4(ii) (2015 version) in that it received premiums in its own name even though it must not do this as a cash agent. The agent did not pay the premiums they received without deduction, claims or set-off whatsoever to their Principals.
The Agents' Registration Board ordered:
Sincl Pte. Ltd. to be suspended for 1 month with effect from 13 April 2021 to 12 May 2021, during which it must not solicit general insurance business or engage in general insurance selling or advisory activities for any new clients. Sincl Pte. Ltd. is solely permitted to engage in general insurance selling or advisory activities for policy renewals of its existing clients.
6. Chew Tee Kee (A009065) - Published on 25 Oct 2021
The ARB found that Chew Tee Kee did contravene GIARR Appendix D 12: Sub Agency, GIARR 2020 9.2 (d) and GIARR Appendix E1 (Agency Agreement) Paragraph 3.2 (f) in that the agent:
a. entered into an arrangement for the engagement of a sub-agent and its nominee agent. The sub-agent collected the insurance premiums and advised on and arranged insurance policies of the Agent’s Principal and belonging to the agent’s customer.
b. did not comply with and observe with the requirements that premium payments other than cash were made payable only to the Agent’s Principal
c. delegated his functions and duties as an agent to another agent, who is not his Nominee Agent.
The Agents' Registration Board ordered:
Chew Tee Kee, to be reprimanded pursuant to GIARR 14.4(c).
7. Zhou Anjian Leonard (C00722-002), Nominee Agent of Multi-Lines Agencies (C000722) - Published on 25 Oct 2021
The ARB found that Zhou Anjian Leonard did contravene GIARR 9.4f, in that the Nominee Agent:
a. engaged in general insurance selling and advisory activities for a member which the Nominee Agent does not represent.
b. entered into an arrangement with an agent, who is not their nominee agent, where he advised on and arranged insurance policies belonging to the other agent’s customer. The insurance policies were placed through the other agent’s principal. He arranged for his Corporate Agency to collect the insurance premiums for these insurance policies.
The Agents' Registration Board ordered:
Zhou AnJian Leonard is to be suspended for 2 weeks with effect from 26 October 2021 to 9 November 2021, during which he must not solicit general insurance business or engage in general insurance selling or advisory activities for any new clients.
He is solely permitted to engage in general insurance selling or advisory activities for policy renewals of its existing clients.
8. SK Solutions Pte. Ltd. (C005018) - Published on 12 Dec 2022
The ARB found that SK Solutions Pte. Ltd. did contravene GIARR 9.2 (b), (c) and (d) in that it received premiums in its own name even though it must not do this as a cash agent.
The Agents' Registration Board ordered:
SK Solutions Pte. Ltd. to be suspended for 1 month with effect from 7 September 2022 to 6 October 2022, during which it must not solicit general insurance business or engage in general insurance selling or advisory activities for any new clients. SK Solutions Pte. Ltd. is solely permitted to engage in general insurance selling or advisory activities for policy renewals of its existing clients.
9. Dragon Insurance Agency (C005597) - Published on 12 Dec 2022
The ARB found that Dragon Insurance Agency did contravene GIARR 9.2 (c) and 9.2 (d), and GIARR 9.1(l) and GIARR Appendix D Section 5 in that the agent:
(a)received premiums in its own name even though it must not do this as a cash agent.
(b)took months to produce some of the audit evidence during the audit, and was unable to furnish many of the documentary evidence to the auditors.
(c)did not maintain proper accounting records of transactions entered with policyholders and principals. The agent did not maintain journal entries and were not able to furnish documentary evidence to the auditor showing receipts of premiums received from policyholders.
The Agents' Registration Board ordered:
Dragon Insurance Agency to be suspended for 2 months with effect from 7 September 2022 to 6 November 2022, during which it must not solicit general insurance business or engage in general insurance selling or advisory activities for any new clients. Dragon Insurance Agency is solely permitted to engage in general insurance selling or advisory activities for policy renewals of its existing clients.
10. HM Pte Ltd (C005644) - Published on 12 Dec 2022
The ARB found that HM Pte Ltd did contravene GIARR 9.2 (d) and GIARR Appendix D Section 12 in that the agent:
a) received premiums in its own name even though it must not do this as a cash agent.
b) entered into an arrangement with an unlicensed agent, where the unlicensed agent collected the insurance premiums on behalf of the agent.
The Agents' Registration Board ordered:
HM Pte Ltd, to be reprimanded pursuant to GIARR 14.4(c).
11. Motorist Pte. Ltd. (C005251) - Published on 12 Dec 2022
The ARB found that Motorist Pte. Ltd. did contravene GIARR 9.2 (d) in that it received premiums in its own name even though it must not do this as a cash agent.
The Agents' Registration Board ordered:
Motorist Pte. Ltd. to be suspended for 2 weeks with effect from 31 October 2022 to 13 November 2022, during which it must not solicit general insurance business or engage in general insurance selling or advisory activities for any new clients. Motorist Pte. Ltd. is solely permitted to engage in general insurance selling or advisory activities for policy renewals of its existing clients. On appeal, the appeal committee appointed by the Management Committee affirmed the decision of the ARB.
12. Secutect (C005032) - Published on 12 Dec 2022
The ARB found that Secutect did contravene GIARR Appendix D Section 2.1d, 3.1b, 4.1b and 12 in that the agent:
a) entered into an arrangement for the engagement of a sub-agent, where the unlicensed agent arranged the insurance policies on behalf of the agent.
b) did not explain the policy contract and application forms to the policyholder. As such:
1. the agent was unable to ensure that the policy proposed is suitable to the needs and resources of the policyholder.
2. the agent would not have been able to ensure that the policyholder understands what he was buying.
3. the agent would not have been able to ensure that the consequences of non-disclosure and inaccuracies were pointed out to the policyholder.
The Agents' Registration Board ordered:
Secutect to be suspended for 3 months with effect from 7 November 2022 to 6 February 2023, during which it must not solicit general insurance business or engage in general insurance selling or advisory activities for any new clients. Secutect is solely permitted to engage in general insurance selling or advisory activities for policy renewals of its existing clients.
13. I-N-S Management (C002443) - Published on 12 Dec 2022
The ARB found that I-N-S Management did contravene GIARR Appendix D Section 12 in that the agent entered into an arrangement for the engagement of a sub-agent, where the unlicensed agent arranged the insurance policies on behalf of the agent.
The Agents' Registration Board ordered:
I-N-S Management to be suspended for 3 months with effect from 12 December 2022 to 11 March 2023, during which it must not solicit general insurance business or engage in general insurance selling or advisory activities for any new clients. I-N-S Management is solely permitted to engage in general insurance selling or advisory activities for policy renewals of its existing clients.
14. RC2 Pte. Ltd. (C002411) – Published on 20 Jun 2023
The ARB found that RC2 Pte. Ltd did contravene GIARR 9.2 (a) and (d) in that it received premiums in its own name even though it must not do this as Cash Agent.
The Agents’ Registration Board ordered:
RC2 Pte. Ltd to be reprimanded pursuant to GIARR 14.4(c).
15. TTS Motor Group Pte. Ltd. (C001239) – Published on 20 Jun 2023
The ARB found that TTS Motor Group Pte. Ltd. did contravene GIARR 9.2 (a), (b), (c) and (d) in that it received premiums in its own name even though it must not do this as a Cash Agent. The agent did not pay the premiums they received without deduction, claims or set-off whatsoever to their Principals.
The Agents’ Registration Board ordered:
TTS Motor Group Pte. Ltd. to be suspended for 1 month with effect from 7 June 2023 to 6 July 2023, during which it must not solicit general insurance business or engage in general insurance selling or advisory activities for any new clients. TTS Motor Group Pte. Ltd. is solely permitted to engage in general insurance selling or advisory activities for policy renewals of its existing clients.
16. Choy Weng Hong Eric (A006227) – Published on 15 Jan 2024
The ARB found that Choy Weng Hong Eric did contravene GIARR 11.1 in that he:
a. acted as a controller of AA International Insurance Agency as its CEO.
b. represented more than 3 principals collectively through his individual agency of AIA, AIG and HSBC Life as his principals and AA International Insurance Agency’s representing MSIG, ERGO and Income as its principals.
The Agents’ Registration Board ordered:
Choy Weng Hong Eric’s registration with ARB shall be cancelled with effect from 15 Dec 2023.
17. CFHQ Pte. Ltd. (C005841) – Published on 17 Mar 2024
The ARB found that CFHQ Pte. Ltd. did contravene GIARR 6.5 (b) in that a staff member of CFHQ:
a. did contact an insurer’s customer to offer to renew the customer’s car insurance
b. did claim that CFHQ represents the insurer as one of their principals
even though the corporate agent did not represent the insurer as an agent.
The Agents’ Registration Board ordered:
CFHQ Pte. Ltd. to be reprimanded pursuant to GIARR 14.4(c).
18. Wealth Stability Pte. Ltd. (C003455) – Published on 15 Jul 2024
The ARB found that Wealth Stability Pte. Ltd. did contravene GIARR 9.2 (d) in that it received premiums in its own name even though it must not do this as a Cash Agent.
The Agents’ Registration Board ordered:
Wealth Stability Pte. Ltd. to be suspended for 2 weeks with effect from 15 July 2024 to 28 July 2024, during which it must not solicit general insurance business or engage in general insurance selling or advisory activities for any new clients. Wealth Stability Pte. Ltd. is solely permitted to engage in general insurance selling or advisory activities for policy renewals of its existing clients.
19. Pan Pac Credit Pte. Ltd. (C005437) – Published on 15 Jul 2024
The ARB found that Pan Pac Credit Pte. Ltd. (C005437) did contravene GIARR 6.5(b), 9.2 (a), (b), (c) and (d) and 11.1 in that
a. Policies were issued under insurers that did not belong to any of their 3 principals in 2023.
b. Pan Pac Credit Pte. Ltd. paid net of commission to the principal.
c. Pan Pac Credit Pte. Ltd. was a cash agent but acted as a credit agent for a majority of the sample cases.
d. Refunds were paid by Pan Pac Credit Pte. Ltd. to the customer instead of directly to the customer by the principal.
The Agents’ Registration Board ordered:
Pan Pac Credit Pte. Ltd. to be suspended for 6 months with effect from 15 Jul 2024 to 14 Jan 2025, during which it must not solicit general insurance business or engage in general insurance selling or advisory activities for any new clients. Pan Pac Credit Pte. Ltd. is solely permitted to engage in general insurance selling or advisory activities for policy renewals of its existing clients.