Publishing Verified Trader Performance — Singapore Regulatory Overview

How NakedPnL is positioned under Singapore law: MAS supervision, the Financial Advisers Act, the Securities and Futures Act, the Payment Services Act, and the PDPA.

NakedPnL operates a public registry of verified investment performance produced by individual traders who voluntarily connect read-only exchange API keys or sign on-chain wallet attestations. Daily NAV snapshots feed a time-weighted return (TWR) calculation; results are recorded in an append-only, SHA-256 chained ledger and Merkle-anchored to Bitcoin via OpenTimestamps so any third party can independently re-verify them.

This page describes how that activity is positioned under Singapore law, with reference to the Monetary Authority of Singapore (MAS), the Financial Advisers Act 2001 (FAA), the Securities and Futures Act 2001 (SFA), and the Payment Services Act 2019 (PSA).

How NakedPnL is classified in Singapore

NakedPnL's activity is the production and distribution of factual performance data. The platform is not licensed by MAS under the FAA, the SFA, or the PSA, and does not appear on any MAS register of licensed entities.

Financial Advisers Act 2001

Section 2(1) of the FAA defines financial advisory service to include advising others on any investment product, including by issuing or promulgating analyses or reports concerning any investment product. Section 6 prohibits any person from acting as a financial adviser in Singapore unless licensed under the FAA or exempt under the regulations.

Whether content is advice for FAA purposes turns on whether it is a personal recommendation or general factual reporting. MAS Guidelines on Provision of Financial Advice (FAA-G14) and the Notice on Recommendations on Investment Products (FAA-N16) elaborate the test. NakedPnL publishes the same registry data to every reader of a given page, does not collect customer risk-profiling data, and does not provide investment recommendations. The platform's analysis is that the activity falls outside the FAA's regulated advisory perimeter.

Securities and Futures Act 2001

The SFA regulates dealing in capital markets products, fund management, custodial services, providing credit-rating services, and the operation of organised markets among other regulated activities. NakedPnL does not deal in capital markets products, does not provide fund management or custody, and does not operate any organised market or recognised market operator.

Where individual traders trade SFA-regulated products on third-party venues, the responsibility for SFA compliance falls on the venue and on the trader, not on the publisher of factual after-the-fact performance data.

Payment Services Act 2019 and Digital Payment Tokens

The Payment Services Act 2019 regulates seven types of payment service in §2(1), including the Digital Payment Token (DPT) service. A DPT service is the dealing in or facilitation of the exchange of digital payment tokens, accepting digital payment tokens for transmission, or providing custodial services for digital payment tokens (the latter added by amendments commencing 4 April 2024).

NakedPnL does not deal in DPTs, does not facilitate the exchange of DPTs, does not accept DPTs for transmission, and does not provide custodial services. Read-only API keys and signature-based wallet attestations grant the platform no authority to move tokens, transmit value, or hold customer assets. The platform's analysis is that the activity is outside the PSA's DPT service definition.

What NakedPnL does not do

• No copy trading. The platform cannot replicate one trader's positions into another user's account.
• No personal recommendations. The platform does not collect customer-suitability data and does not provide tailored advice.
• No broker-affiliate links to MAS-licensed or unlicensed firms in exchange for fees.
• No investor-trader matching. The platform does not arrange transactions between investors and traders.
• No custody — no DPT service under PSA, no custodial service under SFA.
• No execution. The platform never sends orders to any venue.

These design choices are encoded as feature flags in the codebase and protected by a continuous-integration test that fails the build if any flag is changed.

What Singapore users should know

Singapore users should treat the registry as factual performance data and nothing more. Past performance is not necessarily indicative of future performance — the standard MAS disclaimer required of regulated firms when discussing past returns. NakedPnL applies an equivalent statement on every trader profile.

If a third party offers to manage your money based on a NakedPnL track record, check the MAS Financial Institutions Directory (operated by MAS) to see whether that party is licensed under the FAA, the SFA, or the PSA. Trade only with licensed entities for activities that fall within the licensing perimeter. NakedPnL does not vouch for any third-party manager.

Personal Data Protection Act 2012

The Personal Data Protection Act 2012 (PDPA) governs the collection, use, and disclosure of personal data in Singapore. Sections 13–17 establish the consent obligation, with carve-outs for deemed consent and prescribed legitimate interests. Sections 21–22B confer rights of access and correction.

Lawful bases used by the platform include performance of a contract for users with an account, deemed consent for minimal aggregated analytics, and explicit consent for the public listing of a trader's handle and TWR series in the registry. Users can exercise access and correction rights through the privacy contact. Withdrawing public-listing consent under §16 PDPA removes the registry entry from public endpoints.

Complaints may be raised with the Personal Data Protection Commission (PDPC).

Tax considerations

Singapore does not currently impose a capital-gains tax on individuals. Trading gains may nonetheless be taxable as revenue under the Income Tax Act 1947 if the activity is sufficiently frequent, organised, and undertaken with profit-seeking intent — see IRAS e-Tax Guide on the Income Tax Treatment of Digital Tokens. The platform does not produce IRAS-facing statements; users remain responsible for their own returns. A registered Singapore tax adviser is the right resource for specific questions.

Singapore disclaimer variant

Singapore is not currently mapped to a jurisdiction-specific disclaimer variant in lib/jurisdictions.ts. Users in Singapore therefore see the default publisher disclaimer, which states that NakedPnL is a publisher of verified data and not an investment adviser, broker, asset manager, or copy-trading platform. A Singapore-specific variant may be added in a future release if MAS guidance or the regulatory landscape changes; this page will be updated accordingly.

Frequently asked questions