TBGS (Top Borrower Group Survey) updates from Singapore MAS

TBGS (Top Borrower Group Survey) updates from Singapore MAS


TBGS (TOP BORROWER GROUPS SURVEY) – Updates and revised implementation timelines as published by MAS and applicable to banks in Singapore

The reporting requirements of the existing Top 100 Non-Bank Borrower Groups Survey, CR Top Exposures and Credit Migration Returns are revised and consolidated into a single return, known as the Top Borrower Groups Survey (TBGS).

The Monetary Authority of Singapore (MAS) has in April’22 revised the previously proposed timelines for TBGS implementation to allow financial institutions (FIs) more time to test and resolve submission issues. This notice also takes into consideration financial institutions feedback to the Nov’21 circular on the previously proposed TBGS implementation timelines.

There were three phases proposed for this TBGS implementation under the revised timeline:


a – Release of Version 1.0 of XML Schema Definition (XSD) and Excel Submission Template (EST) of TBGS for industry implementation (Phase A): MAS has released update version 1.0 of the XSD and EST of TBGS for industry implementation end of Apr’22. The implementation period of Version 1.0 has been lengthened from previously proposed date of end-June 2022 to 15 October 2022 to account for the increased scope and granularity of the TBGS.


b – Testing and Issue Rectification (Phase B): The dedicated testing period, which lasts from 15th October 2022 to 15th December 2022, will be set aside for FIs to test their submissions of Version 1.0. For institutions that wish to conduct testing earlier, the testing facilities will be available from 1st October 2022. Data reported during the dedicated testing period, need not reflect institutions actual exposures, although actual production data can be used. There are testing scenarios specified by MAS which the banks are expected to adhere to ensure that any submission issues are identified and resolved prior to TBGS go-live.

Listed below are the testing scenarios and timelines within the dedicated testing period.

Date Activity Scope of submission
15 to 28 October 2022 1st submission Sample data for Forms A, B, C, D1, D2 E, and F
All institutions
31 October 2022 to 25 October 2022 MAS’ validation of 1st submission
31 October 2022 to 1 November 2022 2nd submission Sample data for Forms D3 and D4

Institutions in Group I-A and Group I-B

14 to 25 November 2022 MAS’ validation of 2nd submission
28 November 2022 to 15 December 2022 Resubmission of 1st and 2nd submissions in event of any issues As per 1st and 2nd submissions


c – Go-live of the TBGS (Phase C): MAS targets to go-live with TBGS on 30th June 2023. If system or industry wide issues are uncovered during the implementation process, MAS mentioned that they make alternative plans and update FIs on any changes to the timeline. FIs are expected to continue submitting the current Top 100 Non-Bank Borrower Groups Survey, Credit Risk Top Exposures template (if applicable) and Credit Migration Returns (if applicable) until the TBGS goes live.

Submission Formats for Top Borrower Groups Survey

The TBGS will be collected via the Data Collection Gateway (DCG), where data can be submitted through,

  1. Uploading extensible markup language (XML) or Excel submission template (EST), or
  2.  Direct entry via a web-based form.

Institutions have been encouraged to fulfil the TBGS reporting requirements by submitting XML files based on the XML schema definition (XSD) as this is anticipated to facilitate end-to-end automation of data preparation and submission. Nevertheless, data submission through the uploading of Excel files or direct entry via the web-based form is allowed if institutions are not yet ready to submit data in the XML format.


Note: The information presented here, is from published MAS notices