Is Silver Bullion's Secured P2P Loans system regulated by Monetary Authority of Singapore (MAS)?

Our Bullion Secured P2P Loan platform does not fall under the scope of the Monetary Authority of Singapore ("MAS") regulation for several key reasons:

1. Silver Bullion is not a financial institution – The company does not operate as a bank or financial intermediary. It provides a matching platform for borrowers and lenders but does not intermediate, underwrite, or otherwise manage the credit risk of loans.
2. The platform uses bullion as collateral, a physical good – All loans facilitated through the platform are fully collateralised by physical precious metals (such as gold and silver) stored under the custody of Silver Bullion. Since the collateral is a tangible asset rather than a financial instrument, the nature of the transaction falls outside traditional financial services as defined under Singapore’s regulatory framework.
3. Loans are conducted on a one-to-one basis between a single lender and a single borrower – Each loan is a bilateral agreement directly between two parties. This structure differs from collective investment schemes or pooled lending platforms, which typically fall under MAS supervision due to the complexity and scale of their fund management.
4. Customer funds are kept separate – Silver Bullion does not commingle customer funds or reflect them on its balance sheet. This ensures a clear separation of customer funds and company assets, further distancing the platform from traditional financial institution activities that MAS regulates.

While the platform is not subject to MAS licensing requirements, Silver Bullion maintains strong safeguards over loan processes, including strict control of collateral, secure handling of physical bullion, and customer due diligence.