Welcome to Smartkarma’s Compliance Help Centre where you will find answers to key questions commonly asked by our prospective Clients and Insight Providers.
Before emailing us, please read through the FAQ, as the answer is likely here.
Smartkarma is a proprietary online platform (“Platform”) facilitating the distribution of investment related content created by independent research providers (“Insight Providers”) to professional, accredited and/or institutional investors “(Clients”) via paid subscriptions.The Platform is operated by Singapore-incorporated Smartkarma Innovations Pte Ltd. Smartkarma is headquartered in Singapore, with sales and marketing presences in London, Frankfurt, Hong Kong and New York.
In Singapore, Smartkarma is classified as an Internet Content Provider (“ICP”) under the Singapore Media Development Authority’s (“MDA”) Class Licence Scheme. As an ICP, Smartkarma is not required to be actively registered with any regulatory body in Singapore or any other jurisdiction, but is required to comply with the Class License Conditions as stipulated by the MDA from time to time, and as set out in the MDA’s Internet Code of Practice (“Internet Code”).
As an extension of this, Smartkarma requires Insight Providers and Clients to enter into comprehensive User agreements before commencing use of the Platform, which contain important obligations and warranties about use of the Platform and compliant Content. Further information regarding compliance with the Internet Code, and permissible content can be found on the MDA website.
In Singapore, Smartkarma is not required to be licensed as a “financial adviser” under relevant legislation and regulation. The definition of a “financial adviser” under the relevant Singapore law, the Financial Advisers Act (“FAA”), includes a specific exemption for the provider or operator of an online information service. As an online information platform, Smartkarma and the Platform fall squarely within this exception.
Notwithstanding this exemption, it should be noted that in no circumstances does Smartkarma advise individuals or entities as to the advisability of investing in, purchasing, or selling securities or other financial products or services. Further, the Platform is not intended to provide tax, legal or investment advice, and nothing on the Platform should be construed as an offer to sell, a solicitation of an offer to buy, or a recommendation for any security. The content on the Platform is offered only for general information and discussion purposes. As such, Smartkarma is not considered a broker/dealer or investment/financial adviser under Singapore law or under securities laws of other jurisdictions in any circumstances.
Active Users of Smartkarma are comprised of Client subscribers and Insight Providers.
The current Client subscription base is comprised of institutional, accredited and professional investors including hedge funds and asset management funds.
Insight Providers are currently comprised of large independent research houses, boutique research operations and individual freelance analysts, based in Asia, US, Europe and Australia.
Insight Providers are independent third party content providers who have been approved by Smartkarma to write and publish content (in the form of “Insights”) on the Platform. Insight Providers are not employees or agents of Smartkarma, nor under Smartkarma’s supervision or control. Insight Providers range from larger independent research houses to boutique operations to sole/individual freelance writers and analysts.
Smartkarma is a highly curated platform, and to be accepted on Smartkarma, Insight Providers must successfully complete a stringent application process which includes background checks, verification of credentials and industry/work experience and the submission of writing samples. Insight Providers must also complete, as part of their application and then on a yearly (or as required) basis, Smartkarma’s comprehensive Regulatory, Conflicts and Process questionnaire which contains key questions and certifications regarding these topics. As the final step in the on-boarding process, Insight Providers accept a comprehensive User agreement containing key provisions and obligations regarding their conduct and compliant content.
This will depend to some extent on the type of content they are publishing and the jurisdiction in which they are based.
For those Insight Providers based in Singapore, provided content is not personalised, targeted or direct financial investment advice, and because there is the absence of any traditional client/advisor relationship, then such content would not fall within the scope of financial advice for the purposes of relevant Singapore regulation and such Insight Provider would not require licensing.
The same will generally apply in other jurisdictions, however there are some specific jurisdictions where even general, untargeted investment-related content may be regulated and it is up to the individual Insight Providers to verify their compliance if they are based in such a jurisdiction.
Before an Insight Provider can publish an Insight on the Platform, Insight Providers must first certify key statements and disclaimers in respect of that specific Insight, including:
Insight Providers can also add custom disclaimers to the bottom of their Insights, as applicable to their own specific circumstances and regulatory requirements.
Insights published on Smartkarma offer content with a primary focus on Asian financial markets including:
For a breakdown of country and sector coverage of Insights please refer to https://www.smartkarma.com/insight-provider-directory.
Smartkarma curates content most relevant to a particular User based on:
In addition Smartkarma allows a User to set up multiple highly refinable real time alerts to ensure relevant Insight is never overlooked.
Content is distributed to all Clients at the same time. Insights go out via email and alerts, and are made available on the Platform simultaneously. Content is also automatically syndicated onto the Bloomberg terminal at the same time it is published, where it can be further accessed by Clients and other Users. Smartkarma does not use third party filesharing services to distribute content.
Smartkarma’s policy is that Insights are released to all Client subscribers simultaneously. There is however an elective “peer review” process whereby an Insight Provider can elect to submit its content for a period of 24 hour review by fellow Insight Providers and Smartkarma content strategists (“Peer Review”). Under Peer Review, the Insight is reviewed and commented upon as a collaborative and quality control mechanism before it is published to Clients.
Smartkarma does not formally review or exercise direct editorial control over Insights and content before they are published, nor does Smartkarma warrant the accuracy of information published on the platform and all information is provided “as is”.
There are however key measures in place to ensure content is high quality, relevant and compliant, including the following:
Smartkarma maintains a multi-faceted approach to address the important issue of material non-public information (“MNPI”), as outlined below:
Clients may contact Insight Providers by private message. Contact can only be Client-initiated and Insight Providers can only respond to, but not initiate, private messages. The activity of sending and receiving private messages can be tracked by and/or reported to a User’s compliance personnel, and this messaging feature may also be muted at the Client’s election. Through the Premium Services offering, Clients may also initiate and request additional service delivery from Insight Providers such as calls, meetings or custom research. Such requests are facilitated by Smartkarma’s Premium Services manager.
Neither Smartkarma nor its affiliates manage investments.
Insights on Smartkarma do not make or contain formal targeted trading (buy/sell/hold) recommendations. Furthermore, there is notably the absence of any client/adviser relationship between Insight Providers and Clients. However, Insights may occasionally include informal recommendations, as based on an Insight Provider’s personal opinion, which would not be considered targeted trading recommendations as traditionally understood in the financial research industry.
Smartkarma as the operator of the Platform does not, however under the Premium Services offering, Clients may request custom research from Insight Providers.
Only to the extent those third party experts are Insight Providers on the Platform. Under the Premium Services offering, at a Client’s request, Smartkarma facilitates meetings and/or calls between Clients and Insight Providers.
Smartkarma itself does not, however Insight Providers may correspond with or speak to company or government employees in gathering information, however only in relation to publicly available documents and information. Insight Providers are required to disclose such details about their research processes when they complete the Regulatory, Conflicts and Process Questionnaire (upon application and then yearly or more frequently if required).
Smartkarma does not pay third party sources including consultants or survey respondents for information. Smartkarma does pay Insight Providers monthly income for their Insights, with revenue linked to the performance and quality of their work.
Smartkarma does not have any direct relationships with brokers, investment advisers or consultants. Related company SKX Pte Ltd is a party to a Client Introduction Agreement with independent broker and settlement provider ITG Ltd.
Smartkarma does not manage investments, and neither Smartkarma nor Insight Providers are generally considered to provide investment or financial advice through the Platform. Accordingly, Smartkarma places no restrictions that limit the ability of Smartkarma employees or third party Insight Providers to invest in assets. However, when submitting an Insight for publication, all Insight Providers are required to disclose whether they have a relevant interest, or intend to have a relevant interest in any company or security mentioned. This disclosure is public and displayed to all Clients and Users.
Smartkarma uses several compliance tools to facilitate the integration of Client and Insight Provider compliance protocols, including the following:
Smartkarma has an automated “flag” functionality attached to each Insight, allowing Clients and Insight Providers to flag compliance issues or concerns regarding any Insight and its contents direct to Smartkarma’s compliance department. Complaints can also be made via an anonymous hotline or through the dedicated email contact [email protected].