On 6 October, Parliament passed a Bill that lets MAS make DBS, OCBC and UOB hold special debt that can be written off if a bank fails, so that the bank's investors bear the loss instead of the public. I supported it, asked five questions about whether this would work when it is needed, and proposed a regional credit pilot for Singapore's ASEAN chairmanship next year. The Minister of State's reply is at the end.
My questions at a glance
What is Singapore's Basel strategy now that the largest members are departing from the text?
Will MAS require our systemically important banks to publish every half year, on a common template, their government bond holdings country by country and the market value of the bonds they carry at cost? And will MAS publish the same for the whole system?
Has MAS' resolution planning for DBS, OCBC and UOB been tested for legal recognition wherever it would need to be enforced? And has the Government assessed whether writing down foreign holders could be challenged under Singapore's investment treaties?
The Financial Action Task Force asked Singapore to verify who owns companies in ACRA's registries, and to pursue the directors and intermediaries who facilitate money laundering here. How, and by when, will the Government meet those two?
Will the Government put a two-year regional pilot, on shared credit records, a supervisory view of cross-border groups and verified trade records, on the agenda for its ASEAN chairmanship?
The speech, as delivered
Second Reading, 6 October 2026, from Hansard. Section headings and words in [square brackets] are added for readers.
Deputy Speaker, half of this Bill deals with what happens if one of our big banks fail. A bank's first cushion against losses is its capital, mostly shareholders' money. If losses ever used that up, the Government will have to choose between letting the bank collapse, taking deposits and payments with it, and rescuing it with public money.
This Bill lets MAS [the Monetary Authority of Singapore] require our banks to hold a second cushion called the Total Loss Absorbing Capacity, special debt that can be written down or turned into shares if a bank fails, so that its own investors rescue it rather than the public.1 It is called a bail-in, which MAS already has the power to do.
The second cushion is meant to ensure that there is enough such debt to give a failed bank fresh capital and to keep it serving customers while it is restructured.2 The Financial Stability Board wrote this Standard in 2015 for the world's largest banks.3 MAS proposes that capital and this debt, together, come to at least 14% of RWA [risk-weighted assets], and our three local banks already meet it.45
The Bill also writes proliferation financing, the funding of weapons [of] mass destruction into the Act alongside money laundering and terrorism financing.6
Sir, I have five questions and one proposal.
I. When the rule-makers disagree
The first concern is the measure. The Standard is the Financial Stability Board's but the measure it uses is the Basel Committee's. That Committee is where bank supervisors from 28 jurisdictions, MAS among them, agree how much capital banks must hold.7 MAS' own consultation says the Board developed the Standard in consultation with the Basel Committee.8
The cushion is 14% of RWA, which is a Basel number,9 so any disagreement over Basel bears on this Bill, and there is a disagreement. The United States (US) Federal Reserve's Vice Chair for Supervision describes America's approach as tailoring, "requirements to the US financial system, rather than adopting international standards wholesale."10
America's proposed version of the final Basel reforms would lower its largest banks core capital requirements by about 5%.11 Britain has delayed them to 2027 and the European Union has put a temporary multiplier on its trading book rules to protect its banks.1213 Singapore implemented the final reforms in July 2024, ahead of Europe, Britain and America.1415 By the Basel Committee's latest figures, they raise required capital by 3.6% outside Europe and the Americas, against about 1% in each of them.16 At DBS, the floor in those reforms would add about $50 billion of RWA by 2029, largely, the bank says, because of its lending to companies.17
I am not arguing for leaving the club. A small financial centre lives on its reputation and a clean Basel grade lets foreign supervisors rely on ours. But when the rule's authors step back, we should say which course we are on: the text on the Committee's timetable, or what the largest members are actually practising.18
So, my first question: what is Singapore's Basel strategy now that the largest members are departing from the text?
II. What the tape counts as zero
The second concerns what that measure leaves out. The cushion is 14% of RWA. Think of RWA as a measuring tape that counts each asset by how risky the rules say it is. On that tape, government bonds rated AA minus or better count as zero, or close to it, however many a bank holds, US Treasuries included.1920
Nearly all of Silicon Valley Bank's loss sat in bonds the rules counted at zero or one-fifth.21 MAS' consultation points to "the failure of several US banks in 2023", Silicon Valley Bank among them.22 It had put its deposits into long-dated government-backed bonds, booked at the price it paid. When rates rose, as rates are rising now, those bonds lost about US$15 billion, and none of its ratios showed it: its capital ratios were above every minimum, and its leverage ratio, capital against everything it held, was 8.1% against a floor of four.2324
When its depositors, nearly all uninsured, pulled out US$42 billion in a single day, the loss could no longer wait.25 Nor was it alone. At the end of 2022, American banks carried about US$620 billion of paper losses on their bonds and in the end the Federal Reserve lent against those bonds at face value.2627 The loss no ratio counted ended up as public risk.
Our banks are better placed than Silicon Valley Bank was, and MAS already makes them publish what a rate shock would do: at DBS, a rise of around two points costs $1.7 billion, or 2.8% of its core capital.2829 The banks' accounts say how much of their government bonds they carry at cost: about $86 billion across the three. But they do not say what those bonds are worth today, which governments issued them, or what the system would lose on them together.3031 And this is a question of systemic concern.
My second question: will MAS require our systemically important banks to publish every half year, on a common template, their government bond holdings country by country and the market value of the bonds they carry at cost? And will MAS publish the same for the whole system?32
III. Would the cushion work when it is needed?
The third concerns whether the cushion would work when needed. The answer depends on things beyond this Bill. The Financial Stability Board's own report in January says challenges persist in "funding in resolution and effective bail-in execution, particularly in cross-border contexts".33 Credit Suisse shows what that means.
In March 2023, Switzerland arranged UBS' takeover of Credit Suisse, backed by public guarantees, and its regulator wrote off about CHF16.5 billion of the bank's Additional Tier 1 bonds, designed to absorb losses, while shareholders were paid.3435 The order rested partly on an emergency ordinance, not on Switzerland's resolution regime, its law for handling a failing bank in an orderly way, which the Financial Stability Board later said offered "an executable alternative".3637
The same week, the Bank of England did use its resolution powers on Silicon Valley Bank's British arm. It sold the bank to HSBC for one pound, protected depositors, used no public money and wrote its loss-absorbing bonds down to nothing.3839
The Swiss write-off came undone at home. In October 2025, a Swiss court revoked the order, finding the bonds' own trigger had not been met and no statute authorised it; the ruling is under appeal and the bonds are still worthless.40 Abroad, bondholders lost in New York, where courts held Switzerland immune, and investors from Japan, Hong Kong and Singapore have turned to investment treaties.414243 And the doubt spread to all such bonds: within three days, regulators in the EU, Britain, Hong Kong and Singapore had to say publicly that, under their own rules, shareholders would take losses first.44454647
My colleague Jamus Lim will ask whether bonds like these should still count towards the cushion.
I draw three lessons. First, the legal basis must be clear. The bail-in power is in statute, and this Bill adds the cushion.48
Second, recognition must be agreed in advance, and it runs both ways. Part of this cushion will probably be sold abroad. DBS raised US$2 billion in March, and MAS allows the debt to be governed by foreign law, so a bail-in of it would rest on contract clauses and if challenged, on a foreign court.4950 Our own law is rightly careful here: section 103 lets MAS recognise another country's resolution only if that would not harm our financial system, treat our creditors unfairly, go against the public interest, or cost Singapore money.51
Every other country is entitled to the same care, since we are a host as well as a home. MAS proposes that foreign banks' Singapore subsidiaries hold 75% to 90% of their requirements, a figure the Financial Stability Board says should be set "in consultation with the home authority".5253 Clear, published criteria on our side make it easier for others to agree theirs.
Third, who holds the new layer affects whether it will be used. DBS carries almost no Additional Tier 1, about $1 million, and OCBC and UOB about $1.7 billion and $3.4 billion.54 The new layer will be mostly new debt, and its holders are not yet known. MAS will keep bail-in debt sold to retail investors in Singapore out of the new layer, because concern over imposing losses on them "may delay decisions relating to bail-in".55 But such bonds can still be sold here to accredited investors, including individuals who meet an asset or income test, and to retail investors abroad.56
So, my third question: has MAS' resolution planning for DBS, OCBC and UOB been tested for legal recognition wherever it would need to be enforced? And has the Government assessed whether writing down foreign holders could be challenged under Singapore's investment treaties?
IV. What the FATF also asked for
The fourth concerns the Bill's other half, which answers the Financial Action Task Force. Its evaluation of Singapore in May rated us "moderate" on proliferation-financing sanctions.57 It also found that information on who owns companies is largely not verified beyond the checks firms make on their own customers, and that Singapore "prosecutes few legal persons, local directors and professional intermediaries", which is "not in line with its risk and context".5859 Its roadmap sets Singapore 12 key actions, none of them a new law. My colleague Sylvia Lim will speak to the three on proliferation financing. Two others bear on the companies our banks lend to: verifying ownership in the Accounting and Corporate Regulatory Authority's registries, and pursuing the directors and intermediaries who facilitate money laundering here.60
My fourth question: how, and by when, will the Government meet those two?
V. What would actually help Asian banks
Finally, a proposal. This Bill prepares for a bank that fails. After 1997, the International Monetary Fund found that our region's banks had "relied on collateral rather than credit assessment and cash flow analysis", and that connected lending made it worse. Cleaning up cost Indonesia's government more than half a year's output.6162 There are those who would answer Asia's banking risks with an Asian Basel: softer capital ratios for Asian conditions. But I think Asian banking requires different advances.
It requires better lending. Asia's problem is often the allocation of credit, not its quantity: bank lending to the private sector is about 118% of gross domestic product (GDP) in Malaysia, 112% in Thailand and 125% in Vietnam.63 Yet only about one firm in three in Malaysia and Vietnam, and one in seven in Thailand, uses a bank loan to finance investment.64 A bank in our region will readily lend against another building, and turn away an exporter who has orders in hand but little property to pledge.
Our own SMEs [small and medium enterprises] face the same preference: in 2013, 55% of their loans were secured on property; by June this year, about 70% were.65 Cutting capital requirements across the board would simply finance more buildings. Better borrower information, enforceable claims and guarantees aimed at identifiable risks change where the credit goes.
For the same reason, a regional approach should sometimes be tougher, on connected lending, hidden losses and implicit state guarantees.
Singapore chairs the Association for Southeast Asian Nations (ASEAN) next year. The Prime Minister has said of the region that "there are regulatory restrictions and there are ways in which we can make things more seamless".66 Credit is one of those ways. Here are three considerations to advance.
First, a firm's repayment record that crosses a border. Take a supplier in Johor that has served Singapore factories for 10 years and never missed a repayment to its Malaysian bank. A Singapore bank cannot easily see that record, so it will tend to ask for property collateral. If credit bureaus in the region shared such records, with the firm's consent and a common way of identifying it, that supplier could show its history here instead of starting from nothing, and our firms could do the same there. In Hong Kong, banks that make more use of firms' shared records charge lower rates and ask for less collateral.67
Second, a supervisory view of one corporate group across several countries, for supervisors only. Three borrowers in three countries can turn out to depend on one property group and today, no single supervisor sees the combined exposure. The euro area already does this: its central banks collect data on individual bank loans to companies above €25,000, so supervisors can see a company's borrowing across banks and borders.68 Enforcement at home, against powerful interests, remains the hard part.
Third, verified trade records, so the same invoice or shipment cannot be financed twice. In 2020, Hin Leong left 23 banks owed about US$3.5 billion, and some of its cargoes had been financed more than once.69 Our banks have already built such a registry. The Association of Banks in Singapore launched its Trade Finance Registry in June 2023; more than 40 institutions now use it and the ASEAN Secretariat has expressed interest.70
We could start with a two-year pilot involving Singapore, Malaysia, Indonesia and Thailand, covering one trade corridor and one cross-border banking group, and publish the results. It would have to be reciprocal: useful information flowing both ways and credible assurances about how each other's banks would be treated in a crisis.
My fifth question: will the Government put such a pilot on the agenda for its ASEAN chairmanship?
Close
Mr Speaker, this Bill makes our banks safer if they fail. The larger work is to make them more useful while they stand. The Basel rules were rebuilt after 2008 around the failures of wholesale-funded, trading-heavy banks,71 and Asian banks like ours, which lend out their customers' deposits, are not that kind of bank.72 I hope future legislative energy in banking will focus on rules better suited to an Asian context – rules aimed at how our banks actually lend, and how they would actually fail. Thank you, Sir. I support the Bill.
What the Minister of State said in reply
Minister of State Alvin Tan replied for the Government at the end of the debate. These are the passages that bear on my questions, verbatim from Hansard, 6 October 2026.
On the Basel strategy, bond disclosure and the ASEAN pilot (questions 1, 2 and 5)
Mr Kenneth Tiong also raised questions on Singapore's approach towards international standards, disclosure of Government bond holdings by D-SIBs, and suggested proposals on trade corridors and cross-border information sharing during Singapore's ASEAN chairmanship next year. While these are important points, they fall outside the ambit of this Bill. I therefore invite Mr Tiong to file separate Parliamentary Questions if he wishes to explore these topics in greater detail.
In the meantime, I assure him that, as with our approach to TLAC, MAS will continue to participate actively in international fora and implement Basel standards locally, but in a manner that is pragmatic and is suitable and appropriate for Singapore. MAS will also supplement such standards with prudent supervision of credit, liquidity and interest rate risks so our banks remain resilient and at the same time, also remain competitive.
On recognition across borders (question 3)
Sir, let me next address concerns that Mr Saktiandi Supaat and Mr Kenneth Tiong raised on cross-border recognition and cooperation as they relate to bail-in. There are regular, well-established communication channels between MAS and our foreign regulatory counterparts to discuss supervisory and crisis management matters for each D-SIB. Should a D-SIB show signs of distress, there will be increased communication and discussions on what actions to take, be it bail-in or otherwise. MAS will coordinate this action with all relevant regulators of the D-SIB.
MAS requires all TLAC contracts to include a clause stating that these instruments remain subject to MAS' bail-in powers, regardless of their governing law. This will address legal uncertainties on whether such instruments can be effectively bailed in. MAS intends to abide by the creditor hierarchy when exercising its bail-in powers during a resolution. All creditors who receive less in a resolution compared to what they would have received in a liquidation will also be entitled to compensation and MAS will make no distinction between local and foreign investors or between foreign investors of different countries.
On the FATF evaluation (question 4)
Sir, Mr Kenneth Tiong and Ms Sylvia Lim also spoke about FATF's recently completed evaluation of Singapore's Anti-Money Laundering and Countering the Financing of Terrorism and countering proliferation financing framework. I would like to share that the intended amendments to the Financial Services and Markets Act before the House today are unrelated to the outcomes of Singapore's FATF evaluation. They have been planned for a while to technically align our approach with earlier changes to the FATF Standards.
While the outcomes of and follow-ups from the FATF evaluation are not subject to today's debate, I would like to emphasise what Senior Minister of State Murali Pillai said in Parliament in July – that Singapore had performed well in that assessment. And that in the areas where FATF has made recommendations to strengthen specific aspects of Singapore's framework, we are carefully studying them and we will develop plans that are also both risk-proportionate and suited to Singapore's context.
On who may hold the new debt
First, MAS will not allow any TLAC instruments that are issued directly to retail investors to count towards a bank's TLAC. This creates a straightforward disincentive for banks to issue these instruments to retail investors in the primary market.
Second, MAS will make it clear to financial institutions in Singapore that they should not distribute TLAC instruments issued by banks incorporated in Singapore, or investment products that reference these TLAC instruments to Singapore retail investors or facilitate their access to these products.
MAS, Explanatory Brief: Financial Services and Markets (Amendment) Bill 2026, 8 September 2026, paragraph 2: the power complements "MAS' existing power to bail in subordinated debt and eligible senior unsecured debt"; clause 9 inserts sections 57A and 57B, under which a notice may set the level, the calculation method, the eligibility criteria, the investor classes, the resources that count and the disclosure required.
MAS, Explanatory Brief: Financial Services and Markets (Amendment) Bill 2026, 8 September 2026, paragraph 2: the Bill empowers MAS to impose on systemically important financial institutions "the requirement to maintain a minimum level of total loss-absorbing capacity", and "This will complement MAS' existing power to bail in subordinated debt and eligible senior unsecured debt to bolster the solvency of a distressed FI." Financial Stability Board, TLAC Principles and Term Sheet, 9 November 2015, term sheet section 1 (PDF p. 9): the objective is "to ensure that G-SIBs have the loss-absorbing and recapitalisation capacity necessary to help ensure that, in and immediately following a resolution, critical functions can be continued without taxpayers' funds (public funds) or financial stability being put at risk".
Financial Stability Board, TLAC Principles and Term Sheet, 9 November 2015: 16% of risk-weighted assets and 6% of leverage exposure from 2019, 18% and 6.75% from 2022; the leverage-based measure is framed as a backstop to the risk-weighted measure.
MAS, Consultation Paper P011-2026 on Proposed Total Loss Absorbing Capacity Requirements for Domestic Systemically Important Banks in Singapore, 13 May 2026: 14% of risk-weighted assets (3.2); no leverage ratio requirement (3.3); internal TLAC of 75% to 90% (3.6 to 3.7); regulatory capital counts except the CET1 meeting the buffers (3.8); eligible debt (4.2); five years from notification (5.1).
Bank figures as at 30 June 2026 from DBS, OCBC and UOB: DBS Tier 1 capital S$63,517 million against risk-weighted assets of S$381,940 million, so 14 per cent is S$53,472 million (derived). Common equity Tier 1 (CET1) capital above the 9.2 per cent stack of requirements and buffers was S$28.4 billion at DBS, S$17.5 billion at OCBC and S$17.3 billion at UOB (derived).
Financial Services and Markets (Amendment) Bill, Bill No. 19/2026, read the first time 8 September 2026, Explanatory Statement: clause 5 "amends section 16 to provide that the Authority may issue directions or make regulations concerning any financial institution or class of financial institutions for the prevention of proliferation financing, in addition to the prevention of money laundering and terrorism financing"; clause 2 defines "proliferation financing" as "the financing of the proliferation of weapons of mass destruction".
Basel Committee on Banking Supervision, Membership, retrieved 5 October 2026: "The Basel Committee comprises 45 members from 28 jurisdictions, consisting of central banks and authorities with formal responsibility for the supervision of banking business"; Singapore's member is the Monetary Authority of Singapore. Charter, section 1: "The BCBS is the primary global standard setter for the prudential regulation of banks"; section 3: its decisions "do not have legal force".
MAS, Consultation Paper P011-2026 on Proposed Total Loss Absorbing Capacity Requirements for Domestic Systemically Important Banks in Singapore, 13 May 2026, paragraph 2.1: the internationally agreed minimum TLAC requirements for global systemically important banks are "also known as the FSB TLAC Term Sheet"; "The requirements were developed by the Financial Stability Board (FSB) in consultation with the Basel Committee on Banking Supervision."
MAS Consultation Paper P011-2026, 13 May 2026, paragraph 3.2: the requirement is 14 per cent of risk-weighted assets, the measure set by the Basel Committee's capital framework, which MAS applies to Singapore-incorporated banks through MAS Notice 637.
Sullivan & Cromwell, Fed Vice Chair Bowman previews Basel III and G-SIB surcharge proposals, March 2026, on the remarks of 12 March 2026: a "sensible recalibration" that will "maintain capital requirements above the 2019 rules"; the surcharge indexed to economic growth; requirements tailored "to the U.S. financial system rather than adopting international standards wholesale"; trading-book requirements "calibrated to unique U.S. capital markets".
Freshfields, Basel III Endgame, Take Two, on the proposals of 19 March 2026: CET1 changes of −4.8% for the largest banks and −7.8% for smaller ones.
Bank of England, PS1/26: Implementation of Basel 3.1, final rules, 20 January 2026: implementation 1 January 2027; market-risk internal models 1 January 2028.
European Commission, Commission adopts temporary adjustments to Basel III market risk rules to safeguard EU banks' competitiveness, June 2026: application from 1 January 2027 with a multiplier; all other Basel III standards applied in the EU since 1 January 2025.
Moody's, Implementation status of final Basel III reforms varies across globe, 12 July 2023: Australia 1 January 2023; Canada fiscal second quarter 2023; Japan 31 March 2024 (expected); Hong Kong and China 1 January 2024 (expected; Hong Kong's rules took effect 1 January 2025); Singapore 1 July 2024; Switzerland to finalise in 2023 (in force 1 January 2025); the EU and UK 1 January 2025 (expected; the UK since moved to 2027); the United States "has yet to even start the consultation process". Dates as summarised by Moody's.
Bank for International Settlements, press release, 27 March 2020: implementation of the December 2017 standards deferred "by one year to 1 January 2023"; MAS, Circular PPD 08/2023, 8 June 2023: implementation from 1 July 2024, after MAS's deferrals of 7 April 2020 and 19 December 2022. The EU has applied all but its market-risk standards since 1 January 2025, the UK applies its rules from 1 January 2027, and the United States has none in force (notes 11 to 13).
Basel Committee on Banking Supervision, Basel III Monitoring Report, September 2026, p. 4, data at 31 December 2025: "There is a low impact for European banks (+0.8%) and the Americas (+1.2%) while the rest of the world exhibits a greater impact (+3.6%)", with the increase "mainly driven by the output floor (+1.9%) and market risk (+1.7%)". The rest-of-the-world group is Australia, China, India, Indonesia, Japan, Korea, Saudi Arabia, Singapore and South Africa (Basel III Monitoring Report, March 2024, Table B.1); Hong Kong supplies no data (methodology, footnote 3).
DBS Group Holdings, Pillar 3 and other regulatory disclosures, 31 December 2025: overview of RWA at 31 December 2025, credit risk S$264,680 million (of which supervisory slotting S$42,633 million), counterparty credit risk S$14,470 million, credit valuation adjustment S$10,604 million, securitisation S$1,314 million, market risk S$25,129 million all under the standardised approach with no internal models approach, operational risk S$41,641 million, residual S$7,543 million, total S$365,381 million; total RWA calculated using only standardised approaches S$570,698 million, the difference "largely due to Credit risk in the F-IRBA Corporate asset class"; CET1 capital S$62,195 million and CET1 ratio 17.0 per cent, pre-floor ratio the same; Section 18.2, ΔEVE parallel up S$1,747 million against Tier 1 capital of S$62,195 million. On DBS's Pillar 3 disclosures at 30 June 2026, RWA under standardised approaches only were S$600,705 million against S$381,940 million, so the floor at 72.5 per cent would add S$53,571 million (derived); the difference "is mainly driven by Credit risk, largely due to lower risk-weights used to compute RWA for the F-IRBA Corporate asset class".
MAS, Consultation Paper P011-2026, paragraph 3.8: "a DSIB can use its regulatory capital to satisfy its TLAC requirements", except the CET1 that meets the capital conservation buffer. On DBS's 30 June 2026 balance sheet, eligible resources (total capital less the CET1 that meets the 2.7 per cent of buffers) leave S$1,897 million of headroom at today's 60 per cent floor and S$474 million at the 65 per cent step in 2027, and fall short by S$4,541 million at 70 per cent in 2028 and by S$7,049 million at 72.5 per cent in 2029; with the floor at 60 per cent or absent, OCBC and UOB also meet 14 per cent (derived, from DBS's Pillar 3 at 30 June 2026 and MAS Circular PPD 08/2023). The Basel Committee wrote the floor because "a wide range of stakeholders lost faith in banks' reported risk-weighted capital ratios" and its own analyses "highlighted a worrying degree of variability in banks' calculation of RWA" (Basel III: Finalising post-crisis reforms, December 2017). DBS measured its "about $8 billion in excess capital" on its "fully phased-in CET-1", that is, after the floor (4Q24 media briefing transcript, 10 February 2025).
Basel Committee on Banking Supervision, Basel Framework, CRE20: Standardised approach, individual exposures: CRE20.7, sovereign risk weights 0% (AAA to AA−), 20% (A+ to A−), 50% (BBB+ to BBB−), 100% (BB+ to B−), 150% (below B−), 100% (unrated); CRE20.8, national discretion for domestic-currency exposures to the sovereign of incorporation; the corporate table gives 20% for AAA to AA−.
DBS Group Holdings, Pillar 3 disclosures, 31 December 2025, section 12.2.7.2, Foundation IRBA, sovereign exposures with a probability of default from 0.00 to under 0.15 per cent (external ratings AAA to BBB+, section 12.2.11): EAD S$167,742 million, average PD 0.01 per cent, average LGD 45 per cent, RWA S$11,036 million, RWA density 7 per cent; all sovereign exposures, EAD S$174,745 million and RWA S$14,851 million. Under the standardised approach, sovereigns rated AA− or better are weighted at 0 per cent (Basel Framework, CRE20).
SVB Financial Group, Form 10-K for 2022, Note 9: held-to-maturity securities at amortised cost of US$91,327 million and fair value of US$76,169 million, with no US Treasuries; all US$17,206 million of Treasuries held as available for sale. The split of agency pass-throughs between Ginnie Mae (US$9,235 million at amortised cost, loss of US$1,549 million) and Fannie Mae and Freddie Mac (US$48,470 million, loss of US$7,800 million) is from SVBFG's FR Y-9C for 31 December 2022, Schedule HC-B (Internet Archive copy), and matches the FDIC's bank-level data (BankFind API, certificate 24735). Under 12 CFR 217.32, exposures to a US government agency such as Ginnie Mae carry a 0 per cent risk weight, and exposures to a government-sponsored enterprise such as Fannie Mae or Freddie Mac, and general-obligation municipal bonds, 20 per cent. Central estimate of the HTM loss by risk weight (derived): about 28 per cent at 0 per cent and about 71 per cent at 20 per cent, within bounds of 11 to 39 per cent at zero, because the issuer split inside the agency CMOs and CMBS is not disclosed. The FDIC: "SVB's year-end 2022 Call Report reported tier 1 capital of about $17.0 billion; it also reported unrealized holding losses of $2.5 billion on AFS securities and $15.2 billion on HTM securities. None of these losses lowered its tier 1 capital under the regulatory capital regulations" (Options for Deposit Insurance Reform, 1 May 2023, p. 33).
MAS, Consultation Paper P011-2026 on Proposed Total Loss Absorbing Capacity Requirements for Domestic Systemically Important Banks in Singapore, 13 May 2026, paragraph 2.2: "All financial institutions are exposed to risk of failure, not just GSIBs. The failure of several US banks in 2023 further demonstrated the need for authorities to be prepared to resolve non-GSIBs that nevertheless could have significant impact on their respective jurisdictions' financial sectors were they to fail." Paragraph 2.1 grounds the proposal in the Global Financial Crisis and the moral hazard of banks too big to fail.
SVB Financial Group, Fourth quarter 2022 financial results, filed with the SEC, capital ratios at 31 December 2022 (preliminary): SVB Financial Group CET1 12.09%, Tier 1 15.44%, total 16.22%, Tier 1 leverage 8.11%; Silicon Valley Bank CET1 15.29%, total 16.08%, Tier 1 leverage 7.96%; "All of our reported capital ratios remain above the levels considered to be 'well capitalized'"; held-to-maturity securities at fair value US$76,169 million against amortised cost of US$91,321 million. The 4% leverage minimum is the standard "adequately capitalized" threshold for US banks.
Board of Governors of the Federal Reserve System, Review of the Federal Reserve's Supervision and Regulation of Silicon Valley Bank, 28 April 2023, as quoted: the HTM portfolio's weighted-average duration of 6.2 years at 31 December 2022; deposit growth at an 89.3 per cent compound annual rate in April 2020 to December 2021; "the liquidity coverage ratio (LCR), and the net stable funding ratio (NSFR), were not yet applied to SVBFG because of applicable transition periods in the rules"; "under the pre-2019 regime, SVBFG would have been subject to the full LCR and would have had an approximately 9 percent shortfall of HQLA in December 2022, and estimates for February 2023 show an even larger shortfall (approximately 17 percent)"; the risk appetite statement "only included the NII metric and not the EVE metric"; "we should re-evaluate the stability of uninsured deposits and the treatment of held to maturity securities in our standardized liquidity rules".
California Department of Financial Protection and Innovation, Order Taking Possession of Property and Business, Silicon Valley Bank, 10 March 2023 (Internet Archive copy): "withdrawals of $42 billion in deposits from the Bank on March 9, 2023, causing a run on the Bank. As of the close of business on March 9, the bank had a negative cash balance of approximately $958 million". Board of Governors of the Federal Reserve System, Review of the Federal Reserve's Supervision and Regulation of Silicon Valley Bank, 28 April 2023: cover letter, "the combination of social media, a highly networked and concentrated depositor base, and technology may have fundamentally changed the speed of bank runs"; p. 38, "a total deposit outflow of over $40 billion" on 9 March and "an additional over $100 billion in outflows" expected on 10 March; p. 18, the two days "represented roughly 85 percent of the bank's deposit base"; pp. 35 and 37, "approximately 94 percent of SVBFG's total deposits were uninsured"; p. 35, the agency MBS were "low risk from a credit perspective".
FDIC, Remarks by Chairman Martin J. Gruenberg, Institute of International Bankers, 6 March 2023: total unrealised losses on securities, available for sale and held to maturity, of about US$620 billion at year-end 2022.
FDIC, Joint Statement by the Department of the Treasury, Federal Reserve, and FDIC, 12 March 2023: a systemic risk exception enabling the FDIC to resolve Silicon Valley Bank "in a manner that fully protects all depositors", and a similar exception for Signature Bank; Board of Governors of the Federal Reserve System, Bank Term Funding Program term sheet: "The collateral valuation will be par value", with up to US$25 billion from the Exchange Stabilization Fund as backstop.
DBS Group Holdings, Pillar 3 and other regulatory disclosures, 31 December 2025, Section 18.2: the fall in economic value of equity under a parallel upward rate shock is S$1,747 million, against CET1 capital of S$62,195 million, that is 2.8 per cent (derived).
Basel Committee on Banking Supervision, Interest rate risk in the banking book, April 2016: the Pillar 2 standard, six prescribed shocks and an outlier test identifying banks whose decline in economic value of equity exceeds 15 per cent of Tier 1 capital; MAS applies it through Annex 10C of Notice 637 (see DBS's Section 18.2). Under MAS Notice 637, effective 1 January 2026, Table 11-49, the banks publish these changes in economic value and net interest income every year; the figure measures the whole banking book after hedges, not the bond book alone.
Government securities carried at amortised cost at 31 December 2025: DBS S$56,110 million (2024: S$24,392 million), OCBC S$13,664 million and UOB S$16,065 million, S$85.8 billion together (derived). DBS, Annual Report 2025, financial statements, Note 14; OCBC, Annual Report 2025, Note 39; UOB, Annual Report 2025, Note 18(a). None states what those bonds are worth: DBS and OCBC say their fair values were "not materially different" from the carrying amounts, and UOB that they "are expected to approximate" them (DBS Note 40.4, OCBC Note 40.2, UOB Note 19(a)). The only MAS figure is a stressed estimate in the Financial Stability Review 2023, Box C, of 0.6 to 0.7 percentage points a year off the D-SIBs' aggregate CET1 ratio.
DBS Group Holdings, Annual Report 2025, financial statements: Note 14, government securities and treasury bills at FVPL S$19,049 million, amortised cost S$56,110 million and FVOCI S$32,202 million, total S$107,361 million (2024: S$17,852 million, S$24,392 million and S$39,295 million, total S$81,539 million); Note 16, Singapore government securities and treasury bills S$44,536 million, other government securities and treasury bills S$62,829 million; Note 40.4, "For financial assets and liabilities not carried at fair value in the financial statements, the Group has ascertained that their fair values were not materially different from their carrying amounts at year end"; Note 41.4, by the issuer's place of incorporation, Singapore S$44,536 million, Hong Kong S$5,788 million, rest of Greater China S$5,144 million, South and Southeast Asia S$9,906 million and rest of the world S$41,991 million. DBS, 2Q26 performance summary, p. 27: a single balance-sheet line, government securities and treasury bills, S$111,022 million.
MAS, Notice 637, effective 1 January 2026, Part XI: the sovereign asset class appears only by risk-weight bucket (Tables 11-18 and 11-19) or by probability-of-default band (Table 11-21); Table 11-14 breaks down all credit exposures together by geography; Table 11-7 maps balance-sheet lines to regulatory categories in each bank's own format; no table requires the fair value of securities carried at amortised cost. Paragraph 11.2.14 lets a bank omit "proprietary or confidential" items only if it names the omission and gives a reason (paragraph 11.2.15). Basel Committee on Banking Supervision, Voluntary disclosure of sovereign exposures, November 2021: templates SOV1 to SOV3 (exposures by jurisdiction, by currency and by accounting classification), "voluntary in nature, with jurisdictions free to decide whether to require their banks to implement them". They follow the Committee's discussion paper of December 2017, on which it "has not reached a consensus". FFIEC, Call Report instructions, Schedule RC-B: "the amortized cost and fair value of held-to-maturity securities", and of available-for-sale securities, by type, each quarter; Federal Reserve, FR Y-9C: "With certain exceptions, microdata are considered public information". The FDIC publishes the system total each quarter: US$326.7 billion of unrealised losses in the second quarter of 2026 (Quarterly Banking Profile, p. 9). European Systemic Risk Board, Report on the regulatory treatment of sovereign exposures, March 2015, p. 140: in the 2011 stress test "the EBA provided granular data on sovereign holdings (loans, debt securities and derivatives) broken down by country, maturity and IFRS portfolio"; European Banking Authority, EU-wide transparency exercise: bank-by-bank "sovereign exposures broken down by sovereign country issuers"; the exercise "has been discontinued starting from June 2025", with users referred to the EBA Pillar 3 Data Hub.
Financial Stability Board, 2025 Resolution Report: "From Plans to Practice: Operationalising Resolution" (PDF), 21 January 2026. Executive summary: "challenges persist in implementation of critical areas for bank resolution, such as funding in resolution and effective bail-in execution, particularly in cross-border contexts ... In 2026, the FSB will conduct a peer review of public sector backstop funding mechanisms". Section 2.2: "CMGs and supervisory colleges have made progress in sharing information on resolution funding between home and host jurisdictions, but the extent of detail and depth remains uneven"; "Foreign currency funding, including definitions of home and host roles in addressing shortfalls in a crisis, continues to be a critical issue for G-SIBs given their global business models." Section 2.3: "The 2023 bank failures underscored the need to increase efforts among resolution authorities to ensure effective execution of the bail-in tool in a cross-border context." The report's annex records Singapore's statutory bail-in scope as covering unsecured subordinated debt and loans and excluding senior debt, save instruments with contractual bail-in clauses.
Swiss Federal Department of Finance, UBS takeover of Credit Suisse: in March 2023 Credit Suisse "was experiencing an acute crisis of confidence"; the Federal Council's package of 19 March 2023 included "a federal loss protection guarantee for UBS in the amount of CHF 9 billion and a guarantee of CHF 100 billion in favour of the SNB to secure liquidity assistance loans"; UBS, UBS to acquire Credit Suisse, 19 March 2023: an all-share transaction valuing Credit Suisse at CHF 3 billion.
Swiss Federal Administrative Court, Unlawful write-off of AT1 capital instruments, 14 October 2025, case B-2334/2023: about CHF 16.5 billion of Credit Suisse AT1 written off on 19 March 2023; FINMA's order "lacked legal basis"; partial decision, appealable to the Federal Supreme Court. finews.asia, Swiss AT1 decision opens doors for Singapore law firm filing, 20 October 2025: treaty claims for Japanese, Hong Kong and Singapore holders seeking about US$300 million.
FINMA, FINMA to appeal partial decision of the Federal Administrative Court concerning AT1, 15 October 2025: the write-down order of 19 March 2023 was based "in part on the Federal Council's Emergency Ordinance (PLB-EO)"; the court's judgment "does not yet comment on the consequences of this annulment"; FINMA will appeal to the Federal Supreme Court.
Financial Stability Board, 2023 bank failures: preliminary lessons learnt for resolution, 10 October 2023: "the first real test at a larger scale of the international resolution framework established by the Key Attributes"; the framework "provided the Swiss authorities with an executable alternative to the solution that they deemed preferable in the case of Credit Suisse"; the need for an effective public-sector liquidity backstop.
Bank of England, Statement on Silicon Valley Bank, 13 March 2023, and Skadden, Bank of England Resolves Silicon Valley Bank UK Through Sale to HSBC: Silicon Valley Bank UK Limited sold to HSBC UK Bank plc for £1 under the transfer power in the Banking Act 2009; deposits protected and no government funds used.
Bank of England, Bank of England Statement: UK creditor hierarchy, 20 March 2023: the UK framework has "a clear statutory order in which shareholders and creditors would bear losses", "as demonstrated by the resolution of SVB UK, in which all of SVB UK's Additional Tier 1 (AT1) and T2 instruments were written down in full"; AT1 ranks ahead of CET1 and behind Tier 2.
Swiss Federal Administrative Court, Unlawful write-off of AT1 capital instruments, 14 October 2025, on the partial decision of 1 October 2025: the contractual conditions for a write-off were not met because Credit Suisse was "sufficiently capitalised and met regulatory capital requirements", and no statutory provision authorised the order; the request to reverse the write-off is undecided, and "The other cases are now suspended until the decision regarding the revocation of the decree has become final". SWI swissinfo, FINMA appeals decision on Credit Suisse AT1 bonds: about 3,000 complainants in around 360 proceedings. finews, UBS to Appeal Court Ruling on Credit Suisse AT1 Bonds. FINMA and UBS have appealed to the Federal Supreme Court, and the write-off has not been reversed.
Reuters via US News, U.S. Court Rejects $370 Million AT1 Suit Against Switzerland, Swiss Government Says, 1 October 2025: the Southern District of New York dismissed the suit on grounds of sovereign immunity under the Foreign Sovereign Immunities Act. The Court of Appeals for the Second Circuit affirmed in July 2026 (Creditincome Limited v. The Swiss Confederation; Law360, 16 July 2026). As AWP reported the ruling (allnews.ch, in French), in writing down the bonds the Confederation acted "not as a market actor, but in its capacity as a sovereign State", and so enjoys state immunity (translated).
finews.asia, Swiss AT1 decision opens doors for Singapore law firm filing, 20 October 2025: treaty claims for Japanese, Hong Kong and Singapore holders seeking about US$300 million.
Reuters, Japanese investors sue Switzerland over Credit Suisse's AT1 write-down, law firm says, December 2025: 184 Japanese investors filed a request for arbitration at the International Centre for Settlement of Investment Disputes, under the Japan–Switzerland Free Trade and Economic Partnership Agreement. IISD Investment Treaty News, Switzerland faces ISDS claims over Credit Suisse AT1 bond write-off, 19 January 2026.
ECB Banking Supervision, Single Resolution Board and European Banking Authority, Statement on the announcement on 19 March 2023 by Swiss authorities, 20 March 2023: "common equity instruments are the first ones to absorb losses, and only after their full use would Additional Tier 1 be required to be written down".
Bank of England, Bank of England Statement: UK creditor hierarchy, 20 March 2023: the UK framework has "a clear statutory order in which shareholders and creditors would bear losses".
Bloomberg, Hong Kong, Singapore Will Abide by Claims Hierarchy for Banks, 22 March 2023.
MAS, MAS' Statement on Additional Tier 1 Instruments Issued by Singapore Banks, 22 March 2023: "in exercising its powers to resolve a financial institution (FI), it intends to abide by the hierarchy of claims in liquidation. This means that equity holders will absorb losses before holders of Additional Tier 1 (AT1) and Tier 2 capital instruments"; "AT1 bonds in Singapore are offered in the wholesale market, which is only for institutional investors, accredited investors, or transactions in denominations of at least S$200,000"; accredited investors "are individuals or corporates that meet the asset or income criteria in section 4A(1)(a) of the SFA"; "No prospectus for the offering of AT1 bonds to retail investors has been registered with MAS."
MAS, Explanatory Brief: Financial Services and Markets (Amendment) Bill 2026, 8 September 2026, paragraph 2: the Bill complements "MAS' existing power to bail in subordinated debt and eligible senior unsecured debt"; clause 9 inserts sections 57A and 57B into the Financial Services and Markets Act 2022, under which MAS may set the minimum loss-absorbing capacity a bank must hold.
Reuters via MarketScreener, Singapore's DBS raises $2 billion through US dollar bonds, term sheet shows, March 2026: three-year fixed and floating and five-year floating tranches under the global medium-term note programme; Allen & Gledhill, Issue of US$2 billion notes by DBS Group Holdings Ltd.
MAS Consultation Paper P011-2026, 13 May 2026, paragraph 4.2(j): a TLAC instrument must "Be subject to Singapore law or if it is subject to the law of a foreign jurisdiction, the application of resolution powers by MAS is effective and enforceable on the basis of binding statutory provisions or legal enforceable contractual provisions for the recognition of resolution actions".
Financial Services and Markets Act 2022, Part 7, Division 9 (Recognition of foreign resolutions), section 103(3): MAS may determine that a foreign resolution should be recognised in whole or in part if satisfied that recognition "would not have a widespread adverse effect on the financial system in Singapore or the economy of Singapore", "would not result in inequitable treatment of any Singapore creditor relative to any other creditor of the foreign financial institution with similar rights", "would not be contrary to the national interest or public interest" and "would not have material fiscal implications for Singapore"; section 104(1): "If the Minister approves a determination that a foreign resolution should be recognised in whole or in part, the Minister must, as soon as practicable, by order in the Gazette, declare that the foreign resolution is to be recognised", the order extending under section 104(2)(d) to "matters that may be set out in a bail-in certificate". Division 8 (sections 95 to 101) provides for assistance to foreign resolution authorities.
MAS Consultation Paper P011-2026, 13 May 2026, paragraphs 3.6 to 3.7: internal TLAC of 75 to 90 per cent for the Singapore subsidiaries of foreign banks.
Financial Stability Board, Guiding Principles on the Internal Total Loss-absorbing Capacity of G-SIBs, 6 July 2017, Guiding Principle 5: "Host authorities retain ultimate responsibility for setting internal TLAC requirements for the material sub-groups in their jurisdiction and, in doing so, scaling the requirement within the 75% - 90% range consistent with the TLAC term sheet. Establishment of the requirement should be done in consultation with the home authority"; the requirement "should be set at a level that is sufficient to support the resolution strategy for the resolution group and enable the entities in the material sub-group to be recapitalised to meet the conditions for authorisation in the relevant host jurisdiction and command market confidence"; hosts "should consult with the home authorities and consider the implications that the internal TLAC requirement could have for the resolution group"; the standard's objective is to "diminish any incentives on the part of host authorities to ring-fence assets domestically".
MAS, Consultation Paper P011-2026, 13 May 2026: "If a significant portion of TLAC instruments is held by retail investors in Singapore, there is a real risk that considerations over imposing losses on these retail investors may delay decisions relating to bail-in. MAS therefore proposes that TLAC instruments issued to retail investors in Singapore cannot count towards its TLAC"; DSIBs "are not expected to track or limit subsequent transactions of TLAC instruments in the secondary market"; footnote 4: "Retail investors are investors that are not accredited investors (AI) or institutional investors (II)."
MAS, MAS' Statement on Additional Tier 1 Instruments Issued by Singapore Banks, 22 March 2023: "AT1 bonds in Singapore are offered in the wholesale market, which is only for institutional investors, accredited investors, or transactions in denominations of at least S$200,000"; accredited investors "are individuals or corporates that meet the asset or income criteria in section 4A(1)(a) of the SFA". The consultation's exclusion covers instruments issued to retail investors in Singapore (note 55).
FATF and APG, Mutual Evaluation Report of Singapore, May 2026. Ratings table (p. 7): IO.5, transparency and beneficial ownership, Moderate; IO.7, money-laundering investigations and prosecutions, Moderate; IO.11, proliferation-financing financial sanctions, Moderate; Recommendation 24, Partially compliant. Key findings (p. 6): the finding on the accuracy of basic and beneficial ownership information for legal persons, summarised in the text. (p. 13): "Of the 11 189 ML investigations, competent authorities referred 7 594 ML investigations to the AGC for prosecution. Only 682 natural persons were prosecuted during the review period"; "Convictions are largely the result of guilty pleas, which undermines the overall deterrence of sanctions."
FATF and APG, Mutual Evaluation Report of Singapore, May 2026, key findings (p. 6), on the accuracy of basic and beneficial ownership information for legal persons; IO.5, transparency and beneficial ownership, rated Moderate (p. 7).
Same report, Chapter 7. Key findings (pp. 139–140): "Singapore prosecutes few legal persons, local directors and professional intermediaries, which is not in line with its risk and context"; "Singapore has a high incidence of guilty pleas (including plea bargaining), which undermines the overall deterrence of sanctions". Para 461 (p. 144): the pursuit of laundering of fraud proceeds "accounts for over 91% of all investigations", but these "predominantly target domestic money mules (MMs) rather than professional enablers or the controlling minds of the criminal enterprise, who are typically abroad".
FATF and APG, Mutual Evaluation Report of Singapore, May 2026, "Roadmap of key recommended actions (KRAs)", pp. 16–17: "The highest priority measures are identified as Key Recommended Actions"; the roadmap "as adopted by the FATF Plenary in February 2026 ... Singapore is placed in regular follow-up. This KRA Roadmap also serves as the basis for Singapore's follow-up process"; twelve actions, (a) to (c) under IO.5, (d) to (f) under IO.7, (g) to (i) under IO.10 and (j) to (l) under IO.11; IO.5(b), "Review, enhance, and implement additional mechanisms to ensure accuracy (i.e. verification and triangulation) of BO and nominee information in ACRA's central registries"; IO.7(e), "Pursue investigations and prosecutions for local directors and professional intermediaries who are facilitating ML activity within Singapore's borders"; IO.11(j), "Improve supervisory coverage and intensity, and engagement specific to PF TFS for higher risk sectors, particularly VASPs and CSPs". Also on the FATF website.
Carl-Johan Lindgren and others, Financial Sector Crisis and Restructuring: Lessons from Asia, IMF Occasional Paper 188, 2000: "Financial and corporate sector weaknesses combined with macroeconomic vulnerabilities to spark the crisis" (PDF p. 8); "Bank lending practices in the five countries have traditionally relied on collateral rather than credit assessment and cash flow analysis, making banks especially vulnerable to excessive risk taking and declines in asset values"; "Other inadequate lending practices including connected lending, high exposure to individual clients, and excessive sectoral concentration of loans, aggravated the problem"; "Inadequate accounting and disclosure practices (see Box 4) and implicit government guarantees weakened market discipline" (PDF p. 21); on Thailand, "There was also excessive lending based on collateral rather than proper credit assessment; thus, when the asset price bubble burst, banks faced rapid declines in the value of their collateral" (PDF p. 101).
Luc Laeven and Fabián Valencia, Systemic Banking Crises Revisited, IMF Working Paper 18/206, Table 2: gross fiscal costs of 56.8 per cent of GDP for Indonesia (1997–2001), 43.8 for Thailand (1997–2000), 31.2 for Korea (1997–98) and 16.4 for Malaysia (1997–99); fiscal costs are outlays "directly linked to policies to stabilize the financial system".
World Bank, World Development Indicators, Domestic credit to private sector by banks (% of GDP), latest values retrieved through the World Bank API on 25 September 2026: Malaysia 117.9 (2025), Thailand 111.8 (2025), Vietnam 125.0 (2022); Indonesia 31.8 and the Philippines 52.1 (2025).
World Bank Enterprise Surveys, through World Development Indicators, Firms using banks to finance investment (% of firms), retrieved 25 September 2026: Malaysia 32.4 (2024), Vietnam 29.2 (2023), Thailand 13.4 (2025), Indonesia 28.6 (2023), the Philippines 28.9 (2023). The share reflects firms' demand as well as banks' supply, so the gap it shows is consistent with lending tied to collateral rather than proof of it.
MAS, written answer to Mr Yee Jenn Jong, 21 October 2013, from MAS's annual survey of the main lenders to SMEs: "27% of SME loans were unsecured; 55% were secured on property collateral, mainly commercial or industrial properties, and the remaining 18% were secured on other forms of collateral." MAS, Financial Stability Review, November 2025, Chart 3A4: 65.8 per cent secured by property and 19.7 per cent unsecured in June 2025 (60.1 and 29.1 per cent in June 2022). MAS, Financial Stability Review, September 2026, Chart Panel 3A: "The share of unsecured SME loans has been declining, while loans secured by property have been increasing"; the chart shows about 71 per cent secured by property and about 17 per cent unsecured in June 2026 (read from the chart). The surveys may differ in coverage, and the later figures follow definitions revised in 2021. On access, 72 per cent of Singapore small businesses in CPA Australia's survey for 2025 found external finance easy or very easy, the highest of the markets surveyed (Vietnam Investment Review, 6 April 2026).
Bernama, PM Wong Says Singapore To Advance Asean Integration, Inclusive Partnerships During 2027 Chairmanship, 9 June 2026: "There are regulatory restrictions and there are ways in which we can make things more seamless." Malay Mail, Singapore eyes closer Asean-Central Asia ties during 2027 chairmanship, 27 August 2026: Singapore takes over the chairmanship from the Philippines in 2027.
Hong Kong Monetary Authority, Research Memorandum 01/2026, 21 January 2026, on new SME loans from January 2022 to March 2025: "banks that more actively use CDI, on average, charge lower interest rates (by 36 basis points) and require fewer numbers of collaterals (by 1.1 unit) compared to other banks", about 6 and 22 per cent of the sample means; the effects are "more pronounced for young firms". The comparison is between banks rather than loan by loan, and covers only loans with borrower financial data. The Commercial Data Interchange, launched in 2022, is a consent-based platform through which firms pass their own data to banks; by March 2026 it had 27 banks and 17 data providers and had handled over 95,000 loan applications and reviews (Hong Kong Digital Policy Office). On links across borders, the World Bank's General Principles for Credit Reporting (2011), General Principle 5: "Cross-border credit data transfers should be facilitated, where appropriate". The Johor supplier is an illustration, not a named case.
European Central Bank, What is AnaCredit?, last updated 20 November 2020: "AnaCredit is a dataset with detailed information on individual bank loans in the euro area"; it covers loans to companies above €25,000, a threshold chosen to close gaps in data on the financing of small and medium-sized enterprises, and lets supervisors see a company's debts across euro area banks, including across borders.
Global Trade Review, Hin Leong's vicious cycle of trade finance fraud, 19 August 2020, on the interim judicial managers' report: schemes "involved the use of forged documents, non-existent inventory, or the sale of the same inventory to multiple parties"; one cargo of 780,000 barrels of diesel in parallel transactions with letters of credit from Crédit Agricole, Rabobank, DBS, Natixis and OCBC, whose bills of lading "bear the same vessel name and aggregate cargo". Bloomberg, republished by Air Freight News, July 2020: "23 banks on the hook for $3.5 billion". Global Trade Review, 14 July 2020: "Local banks DBS, OCBC and United Overseas Bank are exposed by around US$680mn in total".
Allen & Gledhill, ABS launches Trade Finance Registry to counter trade finance fraud, June 2023: the registry, launched on 23 June 2023, maintains "a centralised record of trade finance transactions in Singapore" to mitigate "the risk of duplicate financing for the same underlying trade"; Global Trade Review, Singapore's anti-fraud trade registry eyes expansion, 16 December 2025: more than 40 participating institutions, up from 14; "going beyond Singapore into other locations is now the next job to be done"; the ASEAN Secretariat has expressed interest; the registry has "highlighted a number of cases of potential duplicate financing frauds".
Basel Committee on Banking Supervision, Basel III: A global regulatory framework for more resilient banks and banking systems, revised June 2011, paragraph 4: "One of the main reasons the economic and financial crisis, which began in 2007, became so severe was that the banking sectors of many countries had built up excessive on- and off-balance sheet leverage"; "many banks were holding insufficient liquidity buffers"; the banking system "was not able to absorb the resulting systemic trading and credit losses nor could it cope with the reintermediation of large off-balance sheet exposures that had built up in the shadow banking system". Basel Committee on Banking Supervision, Basel III: the net stable funding ratio, October 2014, paragraph 1: "The NSFR limits overreliance on short-term wholesale funding"; paragraph 3: "During the early liquidity phase of the financial crisis starting in 2007, many banks – despite meeting the existing capital requirements – experienced difficulties because they did not prudently manage their liquidity." Basel Committee on Banking Supervision, Minimum capital requirements for market risk, 14 January 2016: "The 2007-08 period of severe market stress exposed weaknesses in the framework for capitalising risks from trading activities." "Wholesale-funded" and "trading-heavy" in the text are shorthand for these two findings.
Singapore-dollar loans are 72.5 per cent of Singapore-dollar deposits at DBS (176,809 ÷ 243,856, at 30 June 2026; derived) and 78.7 per cent at UOB on the same date. Market risk is 6.9 per cent of DBS's risk-weighted assets (25,129 ÷ 365,381, at 31 December 2025; derived), all of it on the standardised approach with no internal model. Sources: DBS Group Holdings, Second-quarter 2026 performance summary, 6 August 2026; UOB, Condensed financial statements for the half year ended 30 June 2026, 7 August 2026; DBS Group Holdings, Pillar 3 and other regulatory disclosures, 31 December 2025.