CCS Annual Report 2015-2016

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The Parties are:
a Avallis Financial Pte Ltd,
formerly First Principal
Financial Pte Ltd (“Avallis”);
b CornerstonePlannersPteLtd
(“Cornerstone”);
c Financial Alliance Pte Ltd
(“Financial Alliance”);
d Frontier WealthManagement
Pte Ltd (“Frontier”);
e IPPFinancialAdvisersPteLtd
(“IPP”);
f JPARA Solutions Pte Ltd
(“JPARA”);
g Professional Investment
Advisory Services Pte Ltd
(“PIAS”);
h Promiseland IndependentPte
Ltd (“Promiseland”);
i RAY Alliance Financial
Advisers Pte Ltd (“RAY”); and
j WYNNES Financial Advisers
Pte Ltd (“WYNNES”)
PARTY FINANCIAL
PENALTY
Avallis S$54,788
Cornerstone S$13,781
Financial Alliance S$137,524
Frontier S$5,000
IPP S$239,851
JPARA S$5,000
PIAS S$405,114
Promiseland S$31,305
RAY S$11,939
WYNNES S$5,000
TOTAL S$909,302
This was also shortly after CCS issued
a Proposed Infringement Decision to the
Parties which was publicised.
CCS found that the Parties’ conduct to
prevent a competitor from providing
a lower-cost offer to consumers not
only restricted, but was also likely to
have an adverse effect on competition
in the market. The Parties’ commercial
relationship with iFAST in its unit trust
business contributed significantly to
iFAST’s revenues and placed them in a
position to exert pressure on iFAST. CCS
furthernotedthat theFundsupermartOffer
was particularly attractive to customers
because the general industry practice
of financial advisers is to not provide
commission rebates to policyholders.
In terms of market impact, iFAST
has a wide client base of over 50,000
through and can
reach out to other visitors as well. The
traffic at , including
direct e-mailers and regular visitors, is
estimated to reach up to over 100,000
over a fewmonths. Some of the Parties
themselves had expressed their concern
The Fundsupermart Offer was an innovative one that allowed iFAST to reach out
to awide client base through an established online platform, save on distribution
costs,andpassonthesecostsavingstoconsumersthroughasignificantcommission
rebate. The parties’ conduct to collectively pressurise iFAST into withdrawing the
Fundsupermart Offer prevented the life insurancemarket fromshifting to amore
competitive state.
Agreements between competitors to collectively pressurise a competitor to
withdrawan offering can constitute anti-competitive conduct. Businesses should
instead determine their own individual responses to competition. CCSwill enforce
the law, where necessary, to ensure that new and innovative players can access
markets and compete fairly.
about their own customers switching
to iFAST or seeking from them rebates
similar to those offered by iFAST. Had
iFAST’s offer remained on themarket, the
Partiesmight have had tomake similar or
new offers to respond to the competitive
threat of commission rebates from the
Fundsupermart Offer. The following
financial penalties were imposed on
the Parties:
CCS Chief Executive, Mr Toh Han Li
33
CCS ANNUAL REPORT 2015-2016
GUIDING YOU TO NEW HEIGHTS