Figure 1: The two numbers that decide every Singapore home loan — TDSR at 55% of income and MSR at 30% for HDB and EC purchases.
If you have ever wondered why the bank’s pre-approval letter gave you a smaller loan than you budgeted for — or why a friend on the same salary can borrow noticeably more than you — the answer almost always comes down to two acronyms: TDSR and MSR. These are the two borrowing limits the Monetary Authority of Singapore (MAS) bakes into every residential mortgage, and in 2026 they are the single biggest determinants of how much home you can actually finance.
This guide is the 2026 edition. It covers exactly how TDSR and MSR are calculated, how they interact with the loan-to-value (LTV) cap, where the 4.0% stress-test rate comes from, what counts as income, what doesn’t, and — crucially — how to game the numbers in your favour without breaking any rules. We walk through a fully-worked Singapore example end-to-end and finish with the policy trajectory so you know what to watch for next.
Quick Answer: The 10 Things Every Singapore Borrower Should Know
TDSR is 55%. Total monthly debt repayments — including the new mortgage — cannot exceed 55% of your gross monthly income. Applies to every residential property loan.
MSR is 30%. Mortgage repayments on an HDB flat or Executive Condominium (EC) bought from the developer cannot exceed 30% of gross monthly income. Private condos and landed property have no MSR.
Stress-test rate is 4.0%. TDSR and MSR are calculated at a medium-term interest rate of 4.0% for residential loans, regardless of the rate you actually pay today.
LTV caps layer on top. First housing loan: up to 75% of purchase price. Second housing loan: up to 45%. Third and beyond: up to 35%.
Age and tenure matter. If the loan tenure pushes past age 65, or exceeds 30 years (25 for HDB), the LTV cap drops by 20 percentage points.
Variable income is haircut by 30%. Commission, bonus, rental and freelance earnings are only counted at 70% of the proven figure.
Existing debts eat into headroom. Car loans, credit-card minimum payments, student loans, and other mortgages all hit your TDSR ceiling before the new home loan does.
Guarantors are counted too. If you guarantee a sibling’s loan, it may sit in your TDSR — not theirs.
Cash down-payment rules mirror LTV. The first 5% (25% at higher LTV tiers) must be paid in cash; the balance can be CPF Ordinary Account funds.
Refinancing carve-out. Borrowers refinancing an owner-occupied property with no cash-out may be exempted from TDSR — a narrow but useful escape hatch.
What Is TDSR — The Framework That Underpins Every Home Loan
The Total Debt Servicing Ratio was introduced in June 2013 as part of MAS’s cooling-measures programme (see our full cooling measures timeline for the wider context). Its purpose is simple: to stop households from levering up to a level where a modest rise in interest rates would push them into negative cash flow. The 2010s saw Singapore’s household debt-to-GDP ratio climb past 70%, and MAS wanted a circuit-breaker that worked the same way regardless of which bank a buyer walked into.
TDSR caps all monthly debt obligations at 55% of gross monthly income. “All debt” is deliberately broad: it includes the prospective home-loan instalment (calculated at the stress-test rate), existing mortgages, car loans, personal loans, renovation loans, student loans, credit-card minimum repayments and any loans you have personally guaranteed. Even a dormant credit card with a S$20,000 limit is counted if the bank uses the 3% minimum-payment convention.
The ratio was originally set at 60% in 2013 and tightened to 55% in December 2021, where it remains in 2026. That three-percentage-point shave looks small on paper but at a typical Singapore household income removes roughly S$150,000–S$200,000 of borrowing capacity.
What Is MSR — The Second Ratio You Cannot Ignore for HDB and EC Buyers
The Mortgage Servicing Ratio is narrower but stricter. Introduced for HDB loans in 2011 and extended to bank loans on HDB flats in 2013, MSR caps the mortgage portion alone at 30% of gross monthly income for purchases of HDB flats and Executive Condominiums bought directly from the developer.
MSR is a subset of TDSR, not a substitute. HDB and new-EC buyers must clear both ratios — the tighter of the two binds. In practice MSR is almost always the binding constraint for HDB buyers because existing debt rarely adds up to the 25-percentage-point gap between MSR (30%) and TDSR (55%). For EC buyers the numbers narrow as the project moves through its 10-year maturation period — after the five-year minimum occupation period and the ten-year privatisation, a resale EC is treated like a private condo for borrowing-limit purposes, so TDSR alone applies.
For a side-by-side look at which ratios hit which property type, the matrix below summarises 2026 rules.
Figure 2: 2026 borrowing limits by property type. HDB flats and ECs face both MSR and TDSR; private condos, landed property and commercial assets only face TDSR.
How the 4.0% Stress-Test Rate Works — And Why It Matters More Than Your Actual Rate
Here is the trap that catches most first-time buyers: banks must calculate your monthly instalment using an assumed rate of 4.0% for residential mortgages, even if your actual rate is 2.5% or 3.0%. This is the medium-term interest rate, set by MAS and reviewed from time to time. It was revised upward from 3.5% to 4.0% in September 2022 and has not moved since.
Why 4.0%? The rate is designed to approximate the long-run average that Singapore floating-rate loans have oscillated around over a 30-year horizon. It is deliberately punitive — regulators would rather have borrowers told “you qualify for less” at origination than have the same borrowers go into arrears when rates spike. Anyone who lived through the 2022–2023 rate cycle, when three-month SORA went from 0.2% to 3.8% in 18 months, will appreciate the logic.
The mechanic: the bank plugs a 4.0% rate into the standard amortisation formula using your chosen loan tenure, derives an assumed monthly instalment, and tests that figure against your TDSR (55%) and, if applicable, MSR (30%). Your actual repayment — calculated at whatever rate the bank is offering — will be lower in most cases, leaving you with a margin of safety that MAS consciously engineered.
What Counts as Income — And Why Variable Pay Is Penalised
Income for TDSR/MSR purposes is not what you see on your IRAS tax statement. MAS prescribes a structured treatment:
Fixed salary. Counted at 100%. Evidenced by payslips (usually three to six months) and the latest CPF contribution history.
Variable income. Commission, bonus, overtime, and freelance earnings are haircut by 30%, so only 70% of the verified average is recognised. The haircut applies to the entire variable component, even if you can show multiple years of steady track record.
Rental income. Counted at 70% of the gross rent receivable, net of void periods. A two-year tenancy agreement is strong evidence; month-to-month leases are viewed more sceptically.
Self-employed / business income. Two years of Notice of Assessment (NOA) are the default evidentiary bar, with the 30% haircut applied.
Allowances and AWS. Typically 100% if contractual and evidenced; otherwise haircut.
This is where the seemingly simple 55% number becomes surprisingly individual. A banker earning S$12,000 monthly but with 40% of that as variable gets assessed on S$7,200 fixed + S$3,360 post-haircut variable = S$10,560 — so the TDSR ceiling drops to S$5,808 per month rather than the nominal S$6,600.
What Counts as Debt — The Items Borrowers Miss
The other half of the equation is debt. The headline items — the new home loan instalment, existing mortgages, and car loans — are obvious. Less obvious items often catch borrowers out:
Credit-card minimum payments. Banks use a 3% minimum convention on the outstanding balance (or sometimes on the total credit limit). If you carry S$30,000 revolving credit across cards, that is a S$900 monthly hit on your TDSR — shaving S$192,000 off your loan ceiling at a 4.0% stress rate over 30 years.
Renovation and personal loans. Unsecured loan instalments count in full.
Student loans. Included in TDSR from the date repayments begin.
Guarantor obligations. If you have co-signed a relative’s loan and there is no formal debt-transfer, some banks will count the full instalment against you. Others use 50%. Ask the relationship manager explicitly.
Outstanding ABSD remission obligations. If you are on a remission schedule (e.g. from selling a prior property to claim remission on a new purchase), the existing loan remains in TDSR until the sale completes.
A Fully-Worked Example: A S$10,000-a-Month Household Buying a Private Condo
Figure 3: How different existing-debt profiles crater the monthly headroom available for a new mortgage, given a household earning S$10,000 gross.
Consider a dual-income couple: combined gross monthly salary S$10,000, both on fixed pay, no variable component. They are looking at a S$1.8 million resale private condo in District 15.
Step 1 — TDSR cap. 55% × S$10,000 = S$5,500. No MSR applies because this is a private condo.
Step 2 — Existing debts. One car loan at S$800/month and revolving credit balances generating a S$300/month minimum payment. Total existing obligations: S$1,100.
Step 3 — Headroom for the new mortgage. S$5,500 − S$1,100 = S$4,400 per month available for the new home loan instalment.
Step 4 — Maximum loan principal. At the 4.0% stress rate over a 30-year tenure, S$4,400 monthly funds approximately S$922,000 of loan principal (standard amortisation formula: P = M × [(1 − (1 + r)^(−n)) / r]).
Step 5 — LTV cap. At 75% LTV on an S$1.8m purchase, the bank could lend up to S$1,350,000 — but TDSR limits them to S$922,000 here, so TDSR binds, not LTV. The couple needs S$878,000 of combined cash and CPF equity.
Flip the same household to an HDB flat at S$700,000: now MSR binds first. 30% × S$10,000 = S$3,000 maximum mortgage instalment. That fundamentally funds roughly S$628,000 — well below the 75% LTV ceiling of S$525,000… wait. In this case the 75% LTV actually binds below MSR, because S$525,000 of loan needs only about S$2,500/month at 4.0% over 25 years, comfortably inside MSR. So the couple’s CPF-plus-cash needs to fill the remaining S$175,000.
These two scenarios show the recurring pattern: for HDB/EC buyers, MSR or LTV usually binds; for private/landed buyers, TDSR usually binds. The flow of the calculation matters, and every added dollar of existing debt has a disproportionate impact through the 30-year amortisation lever.
How to Legitimately Maximise Your Borrowing Ceiling
Nothing below involves gaming the system — each lever is recognised by banks and MAS. Together they can add S$200,000–S$400,000 to a buyer’s loan ceiling.
Close dormant credit facilities. A S$50,000 unused overdraft or a clutch of credit cards still hits TDSR via the 3% minimum rule. A week of admin before you apply for pre-approval can move the needle.
Pay down the car loan. High-instalment vehicle finance is the single most common TDSR killer. A S$1,000 monthly car note costs you roughly S$210,000 of home-loan capacity at 4.0%/30yr.
Lengthen the tenure (cautiously). A 30-year tenure beats a 25-year one on headline TDSR because the stress-rate instalment is lower — but watch the age-65 and 30-year triggers that knock the LTV down 20 points.
Co-apply with a higher earner. Joint applications aggregate income and debt. If spouses have different debt loads, consider which combination maximises the pooled headroom.
Formalise variable income. A commissioned sales professional with one year of written contracts may be haircut more heavily than one with two years of NOAs. Waiting one tax cycle can unlock meaningful capacity.
Use a Loan Assessment before committing. Banks in Singapore offer in-principle approval (IPA) at no cost. Three IPAs from different banks let you benchmark the figure.
How Singapore’s Framework Compares Globally
Singapore is not alone in prescribing debt-service ratios, but its combination is unusually strict. Hong Kong applies a 50% debt-service ratio with a 70% LTV cap for first-time owner-occupiers — broadly comparable but no separate MSR for public housing. The United Kingdom uses a 4.5× income loan-to-income ratio at most lenders (soft cap), with affordability stress-tested at 3 percentage points over the reversion rate. Australia’s prudential regulator APRA applies a serviceability buffer of 3 percentage points over the contracted rate — a rule-of-thumb approach rather than a hard ratio.
The common thread in all four jurisdictions is a stress-test mechanism designed to withstand a rate spike. Singapore’s 4.0% medium-term rate is higher (more conservative) than the contracted-rate buffers used in the UK and Australia, which is one reason Singaporean household debt has been more resilient through recent cycles than peers. MAS has been explicit that this is by design: household leverage is viewed as a systemic risk, not purely a consumer-protection issue.
What Might Come Next — The Forward View
The 4.0% stress rate has held since September 2022. Three scenarios could prompt a revision in the next 12–18 months:
Sustained higher long-term rates. If three-month SORA settles above 3.5% on a durable basis, MAS may nudge the medium-term rate to 4.25% or 4.5% to preserve the buffer it represents.
Renewed leverage in the private condo segment. If luxury-segment TDSR headroom is being used aggressively to bid up prime-district prices, expect tighter LTV on second/third loans rather than a TDSR change.
Public housing affordability stress. If HDB resale prices outrun wage growth materially, MSR could tighten from 30% to 25%. This would be the single most consequential move for first-time buyers.
None of the above is signalled by MAS at the time of writing (April 2026) — but the Financial Stability Review due in November 2026 is the data release to watch. Historically MAS has adjusted TDSR and MSR in the December statement that accompanies the cooling-measures package.
Frequently Asked Questions
1. Does TDSR apply to refinancing my existing mortgage?
For owner-occupied properties, a clean refinance without any cash-out and without extending the principal is generally exempted from TDSR under a carve-out MAS introduced to avoid penalising existing borrowers. If you take a cash-out top-up or increase the principal, the full TDSR test applies. For investment-property refinancing, TDSR applies in full regardless of cash-out status, so build in a review of your current debt profile before signing any refinance Letter of Offer.
2. How is TDSR calculated if I am self-employed with irregular income?
Banks use two years of Notice of Assessment (NOA) as the primary evidentiary source, take the simple average, apply the 30% haircut, and treat the resulting figure as your recognised gross monthly income. A particularly strong year — say a bumper bonus — will be smoothed. If you have less than two years of NOAs the bank will often decline or require a significantly larger down-payment. Incorporating yourself through a Pte Ltd does not change this; director’s remuneration drawn as salary is still subject to the haircut.
3. Can I borrow more by stretching the loan tenure?
Up to a point, yes. A 30-year tenure reduces the stress-rate instalment versus a 25-year tenure, increasing how much loan principal S$4,400 (in our worked example) can support. But two triggers cap the benefit: if your loan extends past age 65 or exceeds 30 years (25 for HDB), the LTV cap drops by 20 percentage points — from 75% to 55% on a first loan. The net effect is usually worse, not better. Most brokers recommend landing the tenure such that the loan concludes at or just before age 65.
4. Are joint-borrower applications better than going solo?
Usually, because they aggregate income while both parties still share the TDSR ceiling. The nuance is “income-weighted average age” for tenure calculations — if a 55-year-old and a 35-year-old co-apply, the bank blends their ages by income share to determine the maximum allowable tenure. Adding a much older co-applicant to a younger borrower can shorten the tenure and reduce the headroom on paper. Structured correctly, joint applications reliably produce higher approvals than solo for dual-income households.
5. What happens to TDSR if interest rates fall sharply?
Nothing, in the short run. The 4.0% stress rate is a regulatory input, not a market rate. Falling SORA means your actual monthly instalment shrinks and your actual debt-service ratio improves, but the ceiling at which MAS sets the TDSR bar is unchanged. Over a multi-year horizon, if rates settle well below 4.0% on a sustained basis, MAS may consider lowering the stress rate — but the precedent is that adjustments are infrequent (the last move was September 2022).
6. Does CPF Ordinary Account balance count as income for TDSR?
No. CPF OA is treated as equity (part of the down-payment and subsequent instalments), not as income. The monthly CPF contribution inflow also does not count as additional income — your CPF contributions are already a reduction from your gross pay, and gross pay is what banks use. The only way CPF affects borrowing capacity indirectly is through the Home Protection Scheme (for HDB loans) and through the cash-CPF split in the down-payment.
7. I was denied because of TDSR — what are my options?
First, get the denial reasoning in writing and compare it with a second IPA at a different bank — underwriting interpretations vary on edge cases, particularly around variable income and guarantor obligations. Second, tackle the debt side: clear a car loan, consolidate or close credit cards, discharge a guarantor role. Third, stretch the timeline: a fresh NOA next April may unlock the variable-income shortfall. Fourth, reduce the target property price — a 10% lower purchase price typically requires a proportionally smaller loan and therefore a smaller headroom. Finally, consider a joint application with a fixed-income parent (though this binds their future TDSR too).
This article is an editorial guide for general information only and does not constitute financial, legal or mortgage advice. The figures quoted reflect rules in force on the date of publication (April 2026) and may change. Confirm the authoritative position with the Monetary Authority of Singapore (MAS), the Housing & Development Board (HDB), your bank’s credit officer and a licensed mortgage broker before committing to any loan or property purchase. Interest-rate scenarios and worked examples are illustrative; your actual borrowing ceiling depends on the full underwriting review at application.
HDB owners can sublet whole flat after 5-year MOP (HDB approval required, max 3 years per approval, non-citizen quota applies) or sublet bedrooms after 3-year MOP (5 years for 2-room, no HDB approval needed but online registration required, owner must still live in the flat). Minimum lease is 6 months per tenant — no Airbnb, no short-stay. Breaches risk fines up to S$50,000 and compulsory flat acquisition.
HDB subletting is the single most rule-bound corner of the Singapore rental market. The policies exist because HDB is public housing, funded by subsidies and grants, and subletting concessions try to balance owner flexibility with social objectives (owner-occupation, ethnic integration, housing supply). The rules are enforced — HDB audits tenanted flats and compulsory acquisition is a real outcome for breaches.
This guide lays out the two subletting paths (whole flat vs bedrooms), the occupant caps, and the red lines you cannot cross.
For broader landlord obligations (licensing, tax, TA clauses), see our landlord’s guide. For more context on HDB rules generally, read our MOP rules guide.
Whole-flat vs bedroom subletting, occupant caps, and breach penalties
The two subletting paths at a glance
Rule
Whole-flat subletting
Bedroom subletting
MOP required
5 years (all flat types)
3 years (5 yrs for 2-room)
HDB approval
Required before tenancy
Register online; no approval needed
Owner must occupy
No — owner can live elsewhere
Yes — owner must still live in the flat
Max approval term
3 years per renewal
3 years per tenant
Min lease per tenant
6 months
6 months
Non-citizen quota
Applies (block + neighbourhood)
Does not apply
Ethnic quota (EIP/SPH)
Applies
Applies in certain cases
Whole-flat subletting in depth
Whole-flat subletting is allowed only after the full 5-year Minimum Occupation Period from key collection. Apply via HDB InfoWEB with:
Tenant’s NRIC/FIN and work/student/dependent pass
Proposed tenancy term and rent
S$20 non-refundable admin fee
Declaration of the owner’s temporary residential address
HDB typically approves within 2–3 weeks. The approval is valid for up to 3 years and can be renewed. Non-Citizen Quota (NCQ) may block some rentals if the block or neighbourhood has already reached its foreigner cap.
Bedroom subletting in depth
Bedroom subletting is simpler because the owner stays — HDB treats it more like house-sharing than a full rental. Register the tenant’s details on HDB InfoWEB within 7 days of the tenancy starting. No formal approval needed.
Key constraint: the occupant cap includes both the owner’s household and any subletted bedroom tenants.
Maximum occupants by flat type
Flat type
Max occupants
Max bedrooms rented
1-room / 2-room
4
1 bedroom
3-room
6
1 bedroom
4-room and above
6
2 bedrooms
Where the occupant cap used to be based on flat size, HDB moved to a hard cap of 6 persons in 2024 for most flat types to curb overcrowding and nuisance complaints.
What counts as a breach
Red-line breaches that trigger HDB enforcement:
Short-stay rentals under 6 months — includes Airbnb, Booking.com short lets, weekend stays, room-by-night.
Subletting the whole flat before MOP.
Subletting rooms before 3-year MOP, or 5-year for 2-room flats.
Subletting rooms without the owner residing in the flat.
Exceeding the occupant cap (even by one person).
Letting to tenants without a valid pass or to unauthorised nationalities.
Not registering bedroom subletting on HDB InfoWEB.
Accepting rental payments in cash without records (complicates dispute resolution and IRAS audits).
Penalties
HDB’s enforcement ladder, from lightest to most severe:
Written warning for minor paperwork lapses.
Financial penalty — fines up to S$50,000.
Compulsory acquisition of the flat for serious or repeated breaches. Owner receives compensation at HDB’s determined valuation — typically below market.
Debarment from buying another HDB flat or applying for HDB rental.
Frequently asked questions
Can I rent my HDB flat on Airbnb even if it’s for friends only?
No. The 6-month minimum lease rule applies regardless of who the tenant is. Any stay below 6 months is a breach, even if unpaid.
Can I sublet while I’m overseas for work?
Yes — this is a common use case for whole-flat subletting after MOP. You need HDB approval and must notify HDB of your overseas address. You can return any time.
Does bedroom subletting affect my PR sponsorship or home loan?
No direct effect on PR or citizenship applications. It may affect your TDSR if banks treat rental income as supplementary (they typically use 70–80% of the rent in TDSR calculations).
What’s the non-citizen quota?
HDB caps the percentage of non-Malaysian foreigners who can occupy flats in a block and neighbourhood. If your block has hit the cap, HDB will reject your subletting application until a spot opens up.
Disclaimer
This guide is for general information only. Singapore’s rental rules, HDB policies, and IRAS stamp duty rates change periodically. Always verify against the HDB, URA and IRAS websites before signing a lease or filing with IRAS. LovelyHomes is not a licensed property agent or tax adviser. For personalised advice, please engage a registered CEA agent or a qualified tax professional.
A Singapore Permanent Resident can buy private condos from day one of PR status, paying 5% ABSD on the first residential purchase (30% on second, 35% on third+). HDB resale flats open to PRs only after 3 years of PR status, and require a qualifying family nucleus. PRs cannot buy new BTO, Plus, Prime or EC flats. Landed property on the mainland needs LDAU approval. If you buy an HDB flat as a PR, MOP and subletting rules mirror citizens.
Permanent Residency fundamentally changes a buyer’s property menu in Singapore — but not overnight. From day one, private property opens. HDB resale still waits three years. New HDB (BTO/Plus/Prime) and new ECs remain closed to PRs regardless of wait time.
This guide maps the PR property timeline, the full 2026 ABSD ladder for PR buyers, the most common mistakes PRs make when disposing of existing property, and the rules PRs should know before taking out a CPF loan. For the foreigner-side equivalent, see our foreigner property guide.
A PR’s 3-year path to HDB resale.
The PR property timeline
Day 1 as PR
Private condo, landed-via-LDAU, and Sentosa Cove landed open immediately. CPF usage opens once the PR has active OA/SA balances. LTV, TDSR and MSR frameworks are identical to citizens.
3 years as PR
HDB resale opens. A PR household must form a qualifying family nucleus — typically a PR applicant with a spouse (PR or SG citizen), or the PR-PR Scheme (both applicants PRs for at least 3 years).
5 years after HDB purchase (if you buy HDB)
Minimum Occupation Period. Same 5-year MOP as citizens. Cannot sub-let the entire flat, cannot buy private residential, cannot sell on the open market. See our MOP rules guide.
Lifetime rule
PRs cannot buy new BTO, new Plus, new Prime or new EC flats. These are reserved for SG citizens with a citizen spouse or fiancé(e). The only HDB route for PRs remains the resale market.
ABSD for PRs — the 2026 ladder
Residential count
ABSD (PR)
Notes
1st SG residential
5%
Up from 0% that citizens pay
2nd SG residential
30%
Raised from 25% in Apr 2023
3rd or more
35%
Raised from 30% in Apr 2023
ABSD is payable within 14 days of Option exercise, on top of BSD. If two PRs buy jointly, the ABSD is calculated on the highest-count profile among the buyers.
The HDB-specific rules PRs must follow
Dispose of private within 6 months
A PR who owns private residential (in Singapore or overseas) must dispose of it within 6 months of the HDB resale completion. This is usually the biggest surprise for incoming PR buyers — overseas apartments count.
CPF usage and the lease rule
CPF can fund the purchase only if remaining lease covers the youngest buyer to age 95. For older HDB stock this is a real constraint — see our CPF for property guide.
No grants (mostly)
Most HDB grants (EHG, Family Grant, Proximity Housing Grant) are reserved for SG-citizen first-timer households. A PR-PR couple does not qualify for EHG. However, a PR with an SG-citizen spouse may qualify under the standard first-timer framework — see our grants guide.
Landed and Sentosa Cove
PRs need LDAU approval under the Residential Property Act to buy landed on the mainland — rarely granted except for long-tenured PRs with strong local ties. Sentosa Cove landed is much more accessible: SLA approval is routinely granted for owner-occupation.
Common PR mistakes
Forgetting the 3-year HDB wait. Newly-minted PRs cannot buy HDB until year 3.
Holding overseas property while buying HDB. HDB will compel disposal within 6 months.
Attempting decoupling to reset ABSD. IRAS actively scrutinises PR decoupling post-2022 and may claw back ABSD. See our decoupling guide.
Using CPF on a lease-short flat. Always check the lease-to-95 calculator first.
Frequently asked questions
Can a PR buy an EC?
Not a brand new EC — that’s citizen-only. A PR can buy a privatised EC (post-10-year MOP + privatisation), because by then it is effectively private property.
Can two PRs buy HDB resale together?
Yes — under the PR-PR Scheme, both must have been PR for at least 3 years. Grants are not available.
What if I become a citizen after buying HDB as a PR?
The flat becomes a citizen-owned flat. Any remaining rules (MOP, subletting) still apply from the purchase date.
Does a PR pay the 60% foreigner ABSD?
No. PR status attracts the PR ladder (5% / 30% / 35%) — not the foreigner flat rate.
This guide is for general information only and is accurate as of April 2026. Singapore property rules, taxes and cooling measures change frequently — always verify current figures with URA, IRAS, HDB or a licensed professional before committing. LovelyHomes is not a financial, legal or tax advisor.
Foreigners in Singapore can buy private condos (subject to ABSD 60% on any residential purchase). They cannot buy HDB flats or new BTO / EC. Landed property on the mainland requires approval from the Land Dealings Approval Unit (LDAU); Sentosa Cove landed is open to foreigners with SLA approval. Five nationalities enjoy citizen-equivalent stamp-duty treatment via Free Trade Agreements: US, Switzerland, Liechtenstein, Iceland, Norway.
Singapore has always segmented residential property access by buyer profile. Since April 2023, the rules on foreign buyers have been the tightest they’ve ever been: 60% ABSD on any residential purchase — a near-doubling from the 30% pre-cooling-measure level.
This guide sets out what foreigners can and cannot buy in 2026, the full stamp-duty stack, landed approval process, and the FTA carve-out that makes five nationalities much better off. If you’re close to PR, read our PR property purchase rules for the 3-year HDB wait path.
What a foreigner can and cannot buy in Singapore, with 2026 ABSD stack.
What a foreigner can (and cannot) buy
Property type
Foreigner?
Notes
Private condominium (non-landed)
Yes
Freehold or leasehold. ABSD 60%.
Executive Condominium (new, within 10-yr MOP+privatisation)
No
Only SG citizens/PRs can buy new ECs. Foreigners may buy after 10-year privatisation.
HDB resale flat
No
Not a foreign-ownership property.
HDB BTO / Plus / Prime
No
SG citizens only, with spouse requirements.
Landed — mainland Singapore
With approval
Must apply to the Land Dealings Approval Unit (LDAU) under the Residential Property Act. Rare, case by case.
Landed — Sentosa Cove
Yes with SLA approval
The only legal route for foreign ownership of landed in Singapore. Normally granted for owner-occupation.
Commercial / industrial property
Yes
Outside the Residential Property Act. No ABSD but different duty/GST treatment.
ABSD 2026 — the full stack
Buyer profile
1st residential
2nd residential
3rd+ residential
SG Citizen
0%
20%
30%
SG PR
5%
30%
35%
Foreigner
60%
60%
60%
Entity (company, trust)
65%
65%
65%
ABSD sits on top of the standard Buyer’s Stamp Duty (up to 6% at the top band in 2026). For the BSD calculation see our BSD guide.
The FTA citizen-equivalent carve-out
Under Free Trade Agreements, nationals of the following countries are treated as SG citizens for BSD/ABSD on residential property:
United States of America
Switzerland
Liechtenstein
Iceland
Norway
An American citizen on their first SG residential purchase pays 0% ABSD — the same as a Singapore citizen. IRAS requires a written claim at stamping with supporting documents.
Landed property rules
Under the Residential Property Act, landed property is restricted to citizens by default. Foreigners (and sometimes PRs) need approval from the Land Dealings Approval Unit (LDAU) within the Singapore Land Authority. LDAU approval is case by case, weighs economic contribution, and is rarely granted for pure investment purposes.
Sentosa Cove is the exception: LDAU has historically approved foreign applications fairly readily, for owner-occupation, on the 99-year landed stock.
Loans, LTV and CPF
Bank loans
Foreigners can borrow from local and foreign banks subject to the standard TDSR framework (55% of gross income). Maximum LTV is 75% for the first loan, 45% for the second, 35% for the third, unchanged from the resident framework.
CPF
Not applicable — CPF accounts require PR or citizen status. Foreigners fund the 25% down-payment entirely in cash.
Rental income and exit
Rental income is taxable in Singapore under the non-resident flat 24% rate (or progressive if resident). Capital gains on resale are not taxed. Seller’s Stamp Duty applies if the property is sold within three years — see our SSD guide.
Frequently asked questions
Can a foreigner buy a shoebox unit?
Yes — any private non-landed, subject to ABSD 60%. Our shoebox guide explains the trade-offs.
Can a foreigner inherit landed property?
Yes — but the inheritor must obtain LDAU approval to continue holding it. Without approval, they must dispose within a stipulated window.
What if I’m a dual national?
The strictest relevant nationality generally governs. If one passport gives citizen-equivalent treatment (FTA list), IRAS will honour it with documentation.
Can I use a company to avoid the 60% foreigner ABSD?
No — entities attract 65% ABSD (higher than foreigner). IRAS will look through beneficial ownership, and mis-structuring is treated as evasion.
This guide is for general information only and is accurate as of April 2026. Singapore property rules, taxes and cooling measures change frequently — always verify current figures with URA, IRAS, HDB or a licensed professional before committing. LovelyHomes is not a financial, legal or tax advisor.
Figure 1: The three tenure classes in Singapore real estate — with freehold at ~4% of the housing stock, 999-year a rare pre-1960s relic, and 99-year the dominant form.
Every Singapore property conversation eventually turns to tenure. Is the extra 10–15% for a freehold condo actually worth it? Will a 99-year leasehold unit hold its value if I plan to hold for 20 years? Do banks and CPF really pull the plug on an ageing lease? These are not academic questions. The tenure decision shapes your long-run return more than almost any other call you make at the point of purchase, and the rules that govern it — CPF usage, bank LTV caps, HDB loan eligibility, lease-top-up policy — change in sharp steps rather than smoothly.
This is the 2026 edition of our tenure guide. It walks through the legal substance of freehold, 999-year and 99-year titles; the SLA “Bala’s Table” that dictates how lease-decay is valued; the financing cliffs at 95, 60 and 30 years remaining; and a Singapore-specific worked example that puts a dollar figure on the freehold premium. We close with a forward view on what the SERS / VERS pipeline means for older leaseholds.
Quick Answer: The 10 Things Every Tenure-Sensitive Buyer Should Know
Freehold ≈ ~4% of SG residential stock. The vast majority of private homes and all HDB flats are 99-year leasehold. 999-year titles are a rare pre-1960 relic but, in valuation terms, behave like freehold.
The freehold premium is ~10–15%. In comparable micro-markets, a fresh-lease 99-year condo typically trades at 85–90% of the freehold equivalent — a narrower gap than many buyers expect.
Bala’s Table is the ruler. SLA’s published valuation table is the single authoritative source for how a leasehold interest is valued at any years-remaining. It is a non-linear curve, steepening materially below 60 years.
60 years is the financing cliff. CPF usage and bank LTVs compress sharply once a lease drops below 60 years remaining.
30 years is the exit wall. Below 30 years remaining, almost no bank will finance the unit and CPF usage is effectively nil — the buyer pool collapses to cash-rich owner-occupiers.
SERS is discretionary, not guaranteed. HDB’s Selective En bloc Redevelopment Scheme is offered to a very small minority of ageing flats; the 99 years ends and the land reverts regardless.
VERS is the policy hedge. The Voluntary Early Redevelopment Scheme (legislated 2018, rolling out for the oldest HDB towns in the late 2020s) gives residents a vote on early redevelopment in exchange for a lower pay-out than SERS.
Lease top-ups exist for private land. URA allows lease extensions via upgrading premium payments for selected private freehold/leasehold sites — used routinely by en-bloc developers.
HDB’s 99-year clock starts at award. A BTO completed in 2018 will, in 2117, revert to the state regardless of whether the flat has been sub-sold or renovated.
Tenure affects renter demand less than you’d think. Rental yields on comparable freehold and 99-year properties tend to be within 10–20 basis points of each other; the rental market is insensitive to tenure in a way the sales market is not.
What Tenure Actually Means in Singapore Law
Under the Land Titles Act, freehold in Singapore is what the Common Law calls an “estate in fee simple” — the fullest form of private ownership available, running in perpetuity and capable of being transmitted by will or gift without reverting to the state. 999-year leasehold is functionally indistinguishable from freehold during the lifetime of anyone reading this article; valuers treat it at par with freehold for discounting purposes, and both CPF and bank lenders do the same. Its rarity reflects early colonial-era land grants, most of them pre-1960.
99-year leasehold is the modern default. The State (via the Singapore Land Authority, SLA) retains reversionary title; the leasehold owner holds what is technically a “term of years absolute”. When the lease expires, title reverts without compensation unless the land is re-granted. This is the deal that underpins every HDB flat, every Executive Condominium (from its initial sale onwards), and the majority of private condos and landed properties released from the Government Land Sales (GLS) programme since the 1970s.
How Lease Decay Is Valued: Bala’s Table
Figure 2: The Bala’s Table lease-decay curve as maintained by SLA. A 99-year leasehold retains 90% of its freehold-equivalent value at 80 years remaining, but only 75% at 60 years and 55% at 40 years.
Every Singapore valuer — including IRAS, SLA, CPF, banks and private surveyors — uses the SLA’s “Bala’s Table” as the reference for lease-hold-to-freehold value conversion. The table was named after Mr. Bala Subramaniam, then Chief Valuer, who introduced it in the early 1980s. It expresses the leasehold interest as a percentage of the equivalent freehold value at each remaining-years figure from 99 down to zero. The curve is not linear — depreciation accelerates as years remaining shrinks.
Key reference points from the 2026 version of the table:
99 years remaining: 100.0% of freehold
80 years remaining: ~90.4%
70 years remaining: ~83.6%
60 years remaining: ~75.5%
50 years remaining: ~65.9%
40 years remaining: ~54.6%
30 years remaining: ~41.3%
20 years remaining: ~26.6%
Two practical implications flow from this curve. First, the “depreciation drag” on a 99-year lease over the first 20 years is only about 10 percentage points — which in a market where underlying land values are rising 2–3% annually is easy to out-run. Second, the drag compounds rapidly past the 40-year mark, and by the time a lease is under 30 years remaining the leasehold interest is a fraction of the notional freehold and financing options have all but disappeared.
The Financing Cliffs: 95, 60 and 30 Years
Figure 3: The step changes in CPF usage, bank-loan tenure and HDB-loan eligibility as the years remaining on the lease decline.
Financing rules, not sentiment, drive most of the tenure-based price gap. CPF and bank underwriting both step down abruptly rather than smoothly. The three thresholds every buyer should know:
95 years remaining and above — Full CPF Ordinary Account usage, bank loan tenure up to 30 years or age 65, HDB loan eligible (subject to HDB Flat Eligibility letter). This is the baseline scenario for any brand-new launch.
60 years remaining — The first major cliff. CPF switches to a pro-rated Valuation Limit formula (the property must last the buyer until at least age 95, otherwise CPF usage is capped proportionally). Banks remain willing to lend but the 75% LTV may compress to 55% if the tenure extends past age 65. HDB loans remain available but with reduced LTV for older buyers.
30 years remaining — The exit wall. Most banks will decline to finance the purchase; those that do offer sub-50% LTV at punitive rates. CPF usage is effectively nil. HDB loans are not available. The market for the unit shrinks to cash-rich, typically older, buyers who are treating the purchase as a lifestyle-until-death asset.
The non-linearity is what makes tenure so consequential. A leasehold condo at 65 years remaining looks like a bargain on a pure price-per-square-foot basis — until the buyer realises they have a 5-year runway before the 60-year CPF cliff begins biting, which compresses the future pool of buyers who can take the unit off their hands.
A Fully-Worked Example: Freehold vs 99-Year in District 15
Consider two comparable 3-bedroom condo units in the Marine Parade area, both completed in 2026:
Unit A (99-year leasehold): S$2.3 million purchase price. 99 years at award — so the buyer gets 99 years of tenure starting from 2024 (when the plot was awarded).
Unit B (freehold): S$2.65 million purchase price. 15% premium to Unit A.
Assume both appreciate at 3% per annum nominal (a rough median for the Marine Parade submarket over a 20-year horizon). What does the tenure decision look like at the 20-year mark (2046)?
Unit A (now 79 years remaining): On Bala’s curve at 79 years, the leasehold interest is worth ~90% of the notional freehold equivalent. If the freehold equivalent has compounded at 3% for 20 years, it would be worth S$2.3m × 1.03^20 = S$4.15 million. The leasehold interest is then 90% of that “freehold equivalent” — but wait: the Bala curve already expresses value relative to freehold. So the 99-year unit in 2046 is worth roughly S$2.3m × 1.03^20 × (90%/100%) = S$3.74 million. Gain: ~63% over 20 years.
Unit B (still freehold): S$2.65m × 1.03^20 = S$4.79 million. Gain: ~81% over 20 years.
At the 20-year mark, the freehold unit has outperformed by about S$1.05 million in absolute terms and 18 percentage points in percentage gain. Adjust for the S$350,000 premium paid upfront (which could alternatively have earned ~4% in risk-free assets: S$350k × 1.04^20 = S$767k of opportunity cost), and the net advantage of the freehold is closer to S$300,000–S$400,000 over the period.
Is that worth it? For a buyer with a 20-year hold and no liquidity pressure, plausibly yes. For a buyer whose realistic hold is 8–10 years, the freehold premium may not recoup — the decay drag on a fresh 99-year lease is small over that horizon and the opportunity cost on the premium is live. This is the central trade-off: tenure mattered most for very long holds, very aged leases, or illiquid micro-markets.
SERS, VERS and the End-of-Lease Question
The elephant in the room for ageing 99-year stock is what happens at expiry. Three scenarios exist:
Lease runs its full 99 years and reverts. This is the default. The land returns to the state and the leasehold owner receives no compensation. For HDB flats the owner-occupier gets to live there until expiry (subject to upkeep and lease conditions). For private condos the same applies but the economic value in the final years approaches zero.
SERS (Selective En bloc Redevelopment Scheme). HDB identifies a small number of ageing blocks with high redevelopment potential and offers residents a replacement flat plus ex gratia compensation. Fewer than 5% of HDB blocks have been selected for SERS since the programme began in 1995. The policy framing is deliberately narrow — SERS is a planning tool, not a tenure safety net.
VERS (Voluntary Early Redevelopment Scheme). Legislated in 2018 and first offered to flats around the 70-year-remaining mark in the late 2020s, VERS is an opt-in mechanism: residents of an eligible precinct vote on whether to accept a negotiated pay-out in exchange for early redevelopment. Payouts are explicitly flagged as lower than SERS compensation. Our full VERS guide walks through the mechanics.
For private leaseholds, the equivalent mechanism is the en bloc (collective) sale, where 80% of owners by value (90% if the development is less than 10 years old) can force a sale to a developer who pays SLA a topping-up premium to reset the 99-year clock. The economics of en bloc sales change materially once a development crosses 60 years remaining — the topping-up premium escalates and developer IRRs tighten.
What Might Come Next — Policy Signals to Watch
Three forward-looking data points to monitor over 2026–2028:
The first VERS offers. The first precincts eligible for VERS are the 1970s HDB estates in Tiong Bahru, Queenstown and Marine Parade, now crossing the 55-year-remaining mark. The terms of the first offer (how much is paid, how much choice the resident has in replacement housing) will set the template for the next two decades. HDB has signalled a 2027–2028 rollout window.
Bala’s Table updates. SLA reviews the table periodically. The last meaningful revision was in 2019, when decay rates were nudged upward to reflect data from transactions in older leases. Another revision would have knock-on effects on CPF and bank LTV decisions.
Lease top-up policy for older private estates. A handful of pre-1970s private freehold estates have approached URA for lease-top-up schemes to extend or recalibrate tenure. If a standardised top-up mechanism emerges, the value of ageing 99-year private leaseholds could rise materially.
How Singapore’s Tenure System Compares Globally
Singapore is not alone in using long leaseholds for residential land. Hong Kong’s typical residential lease is also 99 years, with far more aggressive lease-modification and top-up activity (land premiums are a major source of government revenue). London uses a mix of long leaseholds (typically 99 or 125 years) on ex-local-authority and conversion flats, and reformed the Leasehold Reform, Housing and Urban Development Act in 2002 to allow leaseholders to compel freehold purchase (a process called “enfranchisement”) under specific conditions. Vancouver has true freehold in most of the metro area but faces its own lease-renewal issues with First Nations reserve land.
The distinctive feature of Singapore’s framework is the tightness of its financing-tenure coupling: HDB and CPF rules shape the buyer pool in a way that is more formulaic than in most peer jurisdictions. That makes Singapore’s Bala-Table decay an underwriting reality, not just a valuation convention — which is why it moves prices in step-changes around the 60- and 30-year thresholds.
Frequently Asked Questions
1. Is paying a 15% premium for a freehold condo ever worth it?
It depends almost entirely on your holding period and the opportunity cost of the premium. For a 25+ year hold in a supply-constrained micro-market, the math usually favours freehold — the Bala decay on the 99-year unit starts to bite after year 20, the buyer pool for the freehold unit remains wider, and the reinvested-premium scenario struggles to keep pace with property inflation. For a 5–10 year hold, the 99-year unit will typically outperform net of the premium: the Bala decay over that window is less than the opportunity cost of parking an extra S$300,000–S$500,000 in a lower-yielding asset.
2. Can I get a bank loan for a flat with less than 30 years remaining?
In practice, very rarely. Two or three private banks specialising in high-net-worth lending will consider it on bespoke terms — typically capped at 50% LTV, premium rates, short tenure and often secured against other assets. For standard retail buyers, the answer is effectively no. This is why the 30-year mark is called the exit wall: the market shrinks to a niche of cash-rich buyers and the price discount can be severe. The same logic drives why a 99-year unit sold at year 65 clocks a bigger-than-Bala discount — the market is already pricing in the financing thinning that bites at 60.
3. Does CPF allow me to buy an ageing leasehold flat?
Yes, but pro-rated. The CPF Board’s rule of thumb is that the property must be able to last the owner until at least age 95. If the remaining lease does not cover that, CPF usage is capped proportionally via the Valuation Limit/Withdrawal Limit formula. A 40-year-old buyer looking at a 65-year lease on a flat can usually still use full CPF. The same buyer at 55 looking at a 50-year lease will face a material haircut. Always run the CPF calculator before committing.
4. Are all HDB flats 99-year leasehold?
Yes. Every HDB flat — BTO, resale, SBF, DBSS — is 99-year leasehold from the date the block was first awarded (or in some older blocks, re-dated for the current lease commencement). The 99-year clock is set in stone; HDB does not sell freehold, and there is no mechanism to convert an HDB flat to freehold. The compensation schemes (SERS, VERS) are the only policy routes around the expiry, and they are discretionary.
5. How does tenure affect rental yields?
Less than most people expect. Rental markets price comparable units on amenity, location and unit quality; tenure is a distant factor because tenants are paying for the right to occupy, not to own. Comparable freehold and 99-year condos in the same submarket typically show rental yields within 10–20 basis points of each other. The yield difference is usually in favour of the leasehold (because the leasehold trades at a lower capital value), but the gap is small enough that investors optimising for yield rarely pick tenure as the decision variable.
6. What is the difference between lease commencement date and Temporary Occupation Permit (TOP) date?
The lease commencement date is the date on which the 99-year clock begins — typically when the land was awarded to the developer via the GLS programme. The TOP date is when the building is ready for occupation, usually 3–5 years after lease commencement for a condo and 6–8 years for an HDB BTO. The lease clock does not reset at TOP; a buyer moving into a newly-completed 2026 condo may already have only 95 years remaining on the lease because the plot was awarded in 2022. Always check the lease commencement date in the Sale & Purchase Agreement, not just the TOP.
7. Can a 99-year lease be extended?
For private residential land, yes — via the URA’s lease top-up scheme, which en bloc developers use routinely. The developer pays a topping-up premium to SLA and the lease resets to 99 years. Individual flat owners cannot unilaterally request a top-up; it must be done at the collective/development level. For HDB flats there is no top-up mechanism available to flat owners; the 99 years runs to expiry with only the SERS/VERS escape hatches as exceptions.
This article is an editorial guide for general information only and does not constitute legal, financial or valuation advice. The Bala’s Table figures and policy references used are illustrative and reflect the position as published by the Singapore Land Authority (SLA) and the Housing & Development Board (HDB) at the time of writing (April 2026); figures are periodically revised. For authoritative guidance consult the Singapore Land Authority, the HDB, the URA, a licensed property valuer and a qualified conveyancing lawyer before any property decision. Worked-example numbers are illustrative; actual outcomes depend on market conditions, the specific property, and financing available at the time of purchase.
VERS (Voluntary Early Redevelopment Scheme) is the government’s framework for buying back ageing HDB precincts once they reach around 70 years old, so the land can be redeveloped. Unlike SERS, VERS is voluntary — residents vote, a high majority is needed, and compensation is deliberately less generous than SERS because VERS is meant to cover the much wider pool of ageing flats, not just prime redevelopment sites.
For owners of older HDB flats, VERS is the biggest long-term question mark in their asset’s story. It was announced in 2018, and the first VERS precincts are only now coming into frame. The design is clear, even if the specifics for any one precinct will only be known when HDB tables the offer.
How VERS is structured to work, and how it differs from compulsory SERS.
Why VERS exists
HDB flats are on 99-year leases. As a flat ages, its lease decays and its market value falls — the so-called “Bala’s Table” depreciation curve. Without a redevelopment mechanism, older HDB estates would eventually become uninhabitable and worthless at the end of their leases.
SERS (Selective En bloc Redevelopment Scheme) already handles this for a narrow set of high-value sites where the government is confident it can recover the compensation cost by redeveloping the land at much higher density. But only a tiny fraction of HDB flats sit on sites with enough redevelopment potential for SERS economics. VERS is designed to extend the option to a much bigger pool of ageing precincts by offering less generous terms and making the scheme voluntary.
How VERS is designed to work
Precinct reaches ~70 years old. HDB identifies precincts across Singapore that are reaching roughly the last 30 years of lease and are suitable candidates for redevelopment.
HDB studies the site and tables an offer. The offer includes a benchmark compensation figure based on the precinct’s characteristics and market conditions, plus relocation support.
Residents vote. Flat owners in the precinct vote. A high approval threshold (around 75%) is needed for VERS to proceed — a much higher bar than simple majority.
HDB buys back and redevelops. If approved, HDB buys every flat, the precinct is demolished, and the land is redeveloped — for new flats, amenities, or a reshaped precinct layout.
VERS vs SERS in plain language
Feature
SERS
VERS
Nature
Compulsory; HDB selects sites
Voluntary; residents vote
Compensation
Market value + rehousing benefits
Less generous than SERS
Replacement flat
Subsidised nearby new flat
No guaranteed BTO package
Coverage
Only highest-value sites
Wide pool of ageing precincts
Timing
Announced as sites are identified
From ~precinct age 70 onwards
Compensation: why less than SERS?
The Ministry of National Development has been explicit that VERS will pay less than SERS. The reason is arithmetic: SERS works because the redevelopment uplift on a prime site can finance generous compensation. For a typical ageing precinct outside that prime band, the uplift does not stretch as far. If VERS paid SERS-level compensation across the board, the government would be effectively subsidising every ageing HDB owner out of the national reserves.
VERS compensation is still expected to be fair — it must be enough to induce a 75% approval vote, after all — but owners should calibrate expectations below SERS-style windfalls.
Practical impact on lease decay
Until VERS actually starts delivering in the late 2020s and 2030s, owners of older flats have to plan around the standard assumption that a flat’s value tracks Bala’s Table as it ages. VERS is an optionality on that trajectory — a chance, not a guarantee — and should not be priced as a certainty in any financial model.
What to watch before any VERS offer lands
Annual MND / HDB announcements on VERS pilot precincts.
Precinct demographics — an older, ageing-in-place population tends to vote differently from a younger one.
Surrounding land use plans — what the URA intends to do with the reclaimed land affects HDB’s willingness to table an offer.
CPF-refund mechanics — HDB has said CPF/loan refunds will be handled normally, but precinct-specific details will matter for owners with large CPF accrued interest.
Frequently asked questions
Is my flat guaranteed to go through VERS?
No. VERS is site-by-site and vote-by-vote. Some precincts may simply run down to the end of their leases without a VERS offer ever being tabled.
What happens if the VERS vote fails?
The precinct continues on its existing lease. A future VERS offer may or may not be tabled again — MND has not committed to repeat offers.
Does VERS come with a replacement flat?
Unlike SERS, there is no guaranteed subsidised nearby BTO package. Owners will need to buy a replacement flat in the normal market, using VERS proceeds plus any other grants they qualify for.
Is VERS taxable?
Compensation received from the government for a compulsory or voluntary buyback is not treated as taxable income under Singapore’s tax framework.
This guide is for general information only and is accurate as of April 2026. CPF grants, scheme quantum and eligibility rules are set by HDB / the Ministry of National Development and can change. Always confirm current rules on the HDB Flat Portal or with an HDB officer before committing. We are not a financial or legal advisor.
