All banking and financial products, accounts and schemes need no approval from MAS. The statute laws and subsidiary directives are there. Just comply and conform and file the documentation with MAS. MAS never check beyond compliance to laws and directives which don't cover product designs. The banks just file the documents with MAS. If there's something going wrong that breaches laws and directives, MAS then retrieve the filed documents to see whether complaint is valid. Classic case was of course the 2008 Minibond Crisis. MAS don't approve product designs. They're regulators, yes, but they're concerned mostly with money supply and credit. They're most concerned about simple current account overdrafts and credit cards. That's effectively printing virtual money not yet printed.