What the framework does
The Monetary Authority of Singapore's Shared Responsibility Framework (SRF) sets out anti-scam duties for financial institutions, allocating loss responsibility across banks, telcos, and customers on a waterfall basis depending on where a failure occurred. Among its operational requirements: real-time fraud monitoring, a customer-accessible "Kill Switch" to freeze an account rapidly if a scam is suspected, and cooling-off periods triggered by specific account events.
One of the more consequential provisions for everyday banking: a 12-hour cooling-off period is triggered when a customer activates a digital security token or logs in from a new device. During this window, certain higher-risk actions — such as changes to account settings or large fund movements — may be restricted or subject to additional verification.
Why this matters for a call about your annual fee
A fee waiver request itself is not typically the kind of high-risk action the SRF's cooling-off period targets — it doesn't move funds out of your account. But the broader posture the SRF creates is one of banks being more cautious, more verification-heavy, and more willing to introduce friction when something about a request doesn't match the customer's usual pattern.
Practically: if you've recently activated a new digital token, logged in from a new device, or changed your registered mobile number, and then call in shortly after to request account changes, don't be surprised if the agent runs additional verification steps, or in some cases asks you to call back after the cooling-off window has passed for anything beyond a straightforward enquiry.
The Kill Switch and what it means if you're a scam target
The Kill Switch gives customers a fast, self-service way to freeze their own account the moment they suspect fraud, rather than waiting for a call centre agent to action it. If you're ever unsure whether a call claiming to be from your bank is legitimate, the safer move is to hang up and use the Kill Switch or your bank's official app/hotline — not to continue the conversation on the inbound caller's terms.
This also cuts the other way: if you're the one initiating a legitimate call to request a fee waiver, understand that heightened scam-monitoring on the bank's side means agents may ask more identity-confirming questions than they used to, even for routine requests. This is a feature of the new framework, not a sign anything is wrong with your account.
The bigger picture: banks are getting more cautious across the board
The SRF sits alongside the broader MAS push away from SMS OTP and toward app-based, real-time verified authentication. Together, these measures are reshaping what a "routine" banking phone call looks like — more verification steps, shorter windows for certain actions, and less tolerance for ambiguity about who's calling whom.
The clawbacks.ai approach
Our AI agent's calls originate from your registered account details and are placed as legitimate, verifiable customer-initiated contact — not the kind of activity cooling-off periods or Kill Switch protocols are designed to catch. If a bank's verification flow has changed under SRF requirements, our agent adapts to whatever the IVR or live agent asks for.