Singapore has operated a disclosure-based regime modeled after the Western framework for well over a decade. However, the country’s markets and legal system are quite different from those of the United States, where the disclosure-based regime originated.
So the Singapore Exchange SGX, as the front-line regulator of listed companies, brokers and securities trading, has made some adjustments to ensure the disclosure-based regime works.
For example, private enforcement is easier in the US than in Singapore because of contingency fees and the prevalence of class action suits. The shareholdings in the US are also more dispersed compared to the concentrated shareholdings found in Singapore. To balance...