A due-diligence checklist for a variable universal life (VUL) policy is a list of questions that the insurer, the licensed representative, the custodian bank and the investment manager answer in writing, and that your own tax and legal advisers review, before you sign. The 20 questions below are grouped from A to E. Each one has a short note on what a good written answer looks like. The list does not recommend any product or insurer, and it cannot replace advice on your own facts.
How to use this checklist
Record each answer as answered in writing, answered verbally only, or unanswered, and sign only when all 20 are in writing, because a verbal comment that conflicts with the contract will not help later. Give the list to every professional involved (see for-advisers) so that one person owns each answer.
Collect the core documents first. MoneySense lists the Product Summary, the Product Highlights Sheet (for an investment-linked plan's sub-fund) and the policy illustration among the documents that accompany a life policy. For a high-net-worth VUL add the policy contract, the investment mandate, the custody agreement, the manager agreement and the fee schedules of the insurer, the custodian and the manager.
| Document | What to read for |
|---|---|
| Product Summary and policy contract | Death benefit formula, charges, surrender schedule, minimum account value, who may own, termination rights |
| Policy illustration or insurer projection | Which format applies, assumed rates, the 0% scenario, whether charges are shown |
| Investment mandate | Permitted and excluded assets, limits, who may change it |
| Custody and manager agreements | Whose name the assets are held in, fees, access rights, termination |
| Tax and AI documents | Self-certifications, opt-in confirmation, evidence of status |
A. The counterparties (questions 1 to 4)
| # | Question | Evidence to ask for |
|---|---|---|
| 1 | Is the insurer licensed and supervised in Singapore, and is each representative on the official register? | Entries in the MAS Financial Institutions Directory and Financial Institution Representatives Register; a check against the Investor Alert List |
| 2 | What do the insurer's size, systemic-importance status and ratings tell you, and what do they not? | Current rating reports with dates; confirmation of what the Policy Owners' Protection Scheme covers |
| 3 | Who is the custodian bank, where is it licensed, and in whose name are the assets held? | The custody agreement, the custodian's licence and regulator, a sample statement |
| 4 | Who is the investment manager, where is it licensed, and may the insurer restrict its jurisdiction or status? | The manager's licence number and regulator; the insurer's written acceptance criteria |
The MAS directories show whether a Singapore insurer, adviser or representative is regulated, and the Investor Alert List names unregulated persons who may be mistaken for licensed ones. MAS's first list of domestic systemically important insurers (21 September 2023) names four insurers and applies a 25% capital add-on from 1 January 2024; that status describes systemic importance, and neither it nor a rating is a guarantee of any policy. Question 3 matters because custodian and manager failure are third-party risks that product documents commonly leave with the policyholder.
B. The contract (questions 5 to 9)
| # | Question | Evidence to ask for |
|---|---|---|
| 5 | How is the death benefit calculated, and what is deducted? | The formula in the policy, such as the higher of a sum assured and the account value, or the account value plus a fixed amount, subject to the policy being in force and less any debt and charges due |
| 6 | Which benefits are guaranteed? | A written list. The account value is not guaranteed. Guaranteed issue guarantees acceptance without medical underwriting, not the investment result |
| 7 | Which charges apply, on what base, and who can change them with what notice? | A charge schedule covering premium, policy, administration, cost-of-insurance, partial-withdrawal and surrender charges, plus custody, management and trading fees charged outside the policy |
| 8 | What is the surrender-charge schedule and when does it end? | The year-by-year table in the contract |
| 9 | What are the minimum account value, the cash buffer and the grace period, and what happens on a breach? | The policy wording; whether the insurer can sell assets or terminate the policy |
MoneySense's guide to investment-linked policy charges lists the usual charge types and states that fees and charges may not be guaranteed and are subject to change; the Life Insurance Association (LIA) guide notes that significant charges usually fall in the early policy years and that ILPs typically do not provide guaranteed cash values. Both statements are about investment-linked policies in general; check each point against your own contract. See charges and guarantees-and-risks.
C. The illustration and the mandate (questions 10 to 14)
| # | Question | Evidence to ask for |
|---|---|---|
| 10 | Which illustration format applies, does it include a 0% scenario, and does it show all charges? | The full document. Where an LIA-format illustration is issued (regular-premium ILPs, and single-premium ILPs whose death and critical-illness benefit is at least 150% of the premium), it must show a 0% column beside the capped upper and lower rates and state that the policy value can fall to zero; an investment-oriented single-premium ILP, which a guaranteed-issue VUL may be, has had no LIA illustration since 1 February 2014, so ask for the insurer's own projection at 0% in writing |
| 11 | What return assumptions sit behind the illustration, by asset class? | The assumption table, labelled as a hypothetical scenario and not a forecast |
| 12 | Which assets are permitted and excluded, and what concentration limits apply? | The mandate schedule |
| 13 | Who can change the mandate or the manager, with what approvals, and what access does each party have? | The change procedure; whether access is read-only or trading |
| 14 | Which of your existing assets can be contributed in specie, and what happens to the rest? | The insurer's asset-acceptance process and a written view from your tax adviser on any disposal or transfer event |
Ask for the projection to be rerun at a low or zero return with the actual charge schedule; if the policy lapses in that scenario, you have learned how much top-up capacity the structure needs. Read investment-options before settling questions 12 to 14.
D. Your side (questions 15 to 18)
| # | Question | Evidence to ask for |
|---|---|---|
| 15 | Do you meet an accredited investor test, and have you opted in? | The evidence file and the signed opt-in; see eligibility |
| 16 | Is the source-of-wealth file complete and consistent across the bank, the insurer and your advisers? | A single narrative with supporting documents; the Guidelines to MAS Notice 314 define source of wealth as the origin of the customer's entire body of wealth |
| 17 | What is the tax residence of each owner, life assured, beneficiary and controlling person, and which self-certifications will be filed? | Completed CRS and FATCA forms; the IRAS e-Tax Guide treats a cash value insurance contract as reportable |
| 18 | Are there US or UK connections: a US person among the parties, a possible return to the UK, or US-situs assets inside the account? | A written note from a tax adviser in each relevant country; see cross-border-tax |
Questions 15 to 18 are about you, not the product; a mismatch between what the bank, the insurer and the tax return say about your wealth and residence can slow underwriting or create reporting problems later.
E. Exit, succession and disputes (questions 19 to 20)
| # | Question | Evidence to ask for |
|---|---|---|
| 19 | Who owns the policy, who is nominated, can a trust or a variable capital company own it, and what happens if the custodian or manager exits or an owner or life assured dies? | The ownership and nomination forms, the insurer's acceptance of the owner type, and the contractual procedure for replacing a custodian or manager |
| 20 | What are the free-look terms, the withdrawal and surrender rules, and which dispute routes are open to you? | The free-look wording; FIDReC eligibility for your type of policyholder; the governing-law and forum clauses |
MoneySense states that life insurers grant a 14-day free-look period from receipt of the policy documents, with a refund of premiums less medical and other expenses; for an investment-linked policy confirm in the contract how market movements and costs are treated. FIDReC offers free complaint filing with an adjudication limit of S$150,000 per claim for claims filed on or after 1 July 2024; its Terms of Reference admit individuals, sole proprietors, small businesses, charities, trustees and insureds, but not larger companies, and exclude cases relating solely to investment performance. Succession outcomes depend on who owns the policy, the nomination type and applicable law, so obtain legal advice.
Red flags and next steps
Pause the application if any of the following appears:
- A person or firm that claims to be licensed but cannot be found in the MAS directories.
- Verbal statements that conflict with the contract, or any wording that suggests the account value is guaranteed.
- A projection with no 0% or low-return scenario, or with charges left out.
- Claims that a regulator has approved or endorsed the product, or that the structure is free of tax.
- Pressure to sign quickly, to move assets before the questions are answered, or to skip a professional's review.
- Reluctance to put an answer in writing.
A sensible next step is to send the 20 questions to the representative and to your tax and legal advisers at the same time, and to compare the written answers. If you want a second reading of those answers, register an enquiry through the contact details on this site.
Sources and dates
- Directories and Investor Alert List (Financial Institutions Directory, Financial Institution Representatives Register) — Monetary Authority of Singapore (MAS) · accessed 2026-10-22
- Interpreting your insurance documents — MoneySense (MAS) · 2026-05-11
- Enhancements to Policy Illustration (PI) of Investment-Linked Policy (ILP) (LIA member update, undated; accessed 2026-10-22) — Life Insurance Association (LIA) Singapore · undated; accessed 2026-10-22
- PPF Entitlement (page shows © 2019; accessed 2026-10-22) — Singapore Deposit Insurance Corporation (SDIC) · accessed 2026-10-22
- Investment-linked policies: Guide to fees and pricing — MoneySense (MAS) · 2026-09-28
- Your Guide to Investment-Linked Insurance Policies (March 2026, v2.0) — Life Insurance Association (LIA) Singapore · 2026-03-05
- MAS Publishes Inaugural List of Domestic Systemically Important Insurers in Singapore — Monetary Authority of Singapore (MAS) · 2023-09-21
- Guidelines to MAS Notice 314 on Prevention of Money Laundering and Countering the Financing of Terrorism — Monetary Authority of Singapore (MAS) · 2025-07-01
- IRAS Common Reporting Standard e-Tax Guide (Fifth Edition) — Inland Revenue Authority of Singapore (IRAS) · 2026-08-11
- Terms of Reference v2.2 (revised with effect from 1 July 2025), via knowledge-base article KA-01002 — Financial Industry Disputes Resolution Centre (FIDReC) · 2025-07-01
- FAQs (KA-01013): who may file, claim limits and fees (accessed 2026-10-22) — Financial Industry Disputes Resolution Centre (FIDReC) · accessed 2026-10-22