Paper 2 · Section 4.1

New Launch Uncompleted

Last reviewed: · Verify policy details against official sources before exam.
Personal study notes. Not professional, legal, financial, tax, or investment advice. Verify all rules and rates against the official Singapore agency (CEA, IRAS, HDB, URA, MAS, SLA, CPF Board) before relying.

HDCLA · Project Account · OTP & S&P · Progressive Payment · TOP · CSC · ABSD Remission · Executive Condominiums

4.1aHDCLA & Developer Licensing

Housing Developers (Control and Licensing) Act (HDCLA)

The HDCLA regulates developers who sell or offer to sell uncompleted residential properties. Any person or company doing so must obtain a Housing Developer's Licence from the Controller of Housing.

Key developer obligations under HDCLA:

  • • Obtain Housing Developer's Licence before selling
  • • Open and maintain a Project Account per development
  • • Deposit ALL purchase monies from buyers into the Project Account
  • • Withdraw from Project Account only for project-related purposes
  • • Use prescribed Sale & Purchase Agreement (S&P) form
  • • Provide buyers with brochure, floor plans, and unit specifications

Project Account — Buyer Protection

Under HDCLA s.9, every licensed developer must maintain a Project Account at an approved bank for each project. All buyer payments must be deposited here — preventing developers from commingling funds or diverting buyer monies to other projects.

Withdrawals are permitted only for purposes directly related to the development (e.g., construction costs, professional fees, land payments).

4.1bSale Licence vs No-Sale Licence

Licence TypeWhat It AllowsTypically Issued To
Sale LicenceDeveloper may sell units after obtaining Building Plan Approval from the Commissioner of Building Control under the Building Control ActEstablished developers with a good track record
No-Sale LicenceDeveloper may construct but CANNOT sell units until additional conditions are met (e.g. TOP or other compliance milestones)Developers with lesser track records or past compliance breaches
Exam tip: Sale Licence = can sell immediately after Building Plan Approval. No-Sale Licence = construction only, cannot sell — a restriction imposed on riskier developers.

4.1bOTP & S&P Process — New Launch

1
Booking: Buyer pays booking fee (min 5%, max 10% of purchase price). Developer issues OTP. If buyer does NOT exercise: developer refunds 75% of booking fee (for private residential). Exception — ECs: 5% of price is forfeited.
2
OTP Exercise Period: Buyer has 21 days (3 weeks) to exercise the option. OTP is NON-assignable and NON-transferable (must be exercised by the named person only; wef 28 Sep 2020, developers are NOT allowed to re-issue OTPs).
3
Exercise OTP: Buyer signs the prescribed S&P Agreement + pays balance deposit (15%, bringing total to 20%).
4
Progressive Payments: Remaining 80% paid in stages tied to construction milestones.
5
TOP & VP: Developer obtains TOP → issues Notice of Vacant Possession → keys handed over.
6
CSC & Legal Completion: CSC issued → legal completion → individual strata titles issued.
Exam trap — OTP exercise period: New launch = 21 days. Resale private property = 14 days. HDB resale = negotiated (varies). Do not confuse.
Deferred Payment Scheme (DPS) — historically allowed buyers to defer bulk payment to TOP. Discontinued October 2007. Only Normal Progressive Payment (NPP) is available today.

⚠ Booking Fee — Key Rules

→ Minimum 5%, maximum 10% of purchase price

→ If OTP not exercised (private residential): developer refunds 75% of booking fee

→ If OTP not exercised (EC): developer forfeits 5% of purchase price (not just 75% refund)

→ OTP is non-assignable / non-transferable — named person must exercise it

→ Re-issuance of OTPs is prohibited (wef 28 Sep 2020); URA may grant validity extension of up to 12 weeks if both parties agree

4.1cNormal Progressive Payment (NPP) Schedule

Construction Stage / EventPaymentCumulative
Booking fee (OTP issued)5%5%
Exercise OTP — sign S&P15%20%
Foundation completed10%30%
Reinforced concrete framework completed10%40%
Partition walls completed5%45%
Roofing completed5%50%
Doors, windows, ceilings, plastering completed5%55%
Car park, roads, drains, recreational facilities5%60%
Notice of Vacant Possession (after TOP)25%85%
Certificate of Statutory Completion (CSC)15%100%

4.1dShortfall in Floor Area — Buyer Remedies

Under the Housing Developers Rules, if the actual floor area of a completed unit is less than stated in the S&P Agreement, the developer's liability depends on the size of the discrepancy:

Shortfall vs S&P stated areaResult
Less than 3% of stated areaNo reduction — buyer has no claim
More than 3% of stated areaReduction at (Unit Purchase Price ÷ S&P area) per sqm for the excess above 3%

Worked Example

Unit Purchase Price: $2,000,000

Floor area stated in S&P: 100 m²

Actual floor area on completion: 95 m²

Shortfall = 5 m² (5% of 100 m²) → exceeds 3% threshold

Rate per sqm = $2,000,000 ÷ 100 = $20,000/m²

Compensable shortfall = 5 m² − 3 m² = 2 m²

Compensation payable = 2 × $20,000 = $40,000

4.1d★Remedies for Breach — Seller & Buyer (All 5 Types)

Breach TypeBy WhomRemedy / Consequence
Shortfall in floor areaDeveloper (Seller)≤3%: no claim. >3%: price reduction at (Unit Price ÷ S&P area) per m² for excess above 3%
Defects in workmanship / materialsDeveloper (Seller)Developer must rectify within 12-month Defects Liability Period (from VP date or 15th day after TOP notice)
Failure to deliver vacant possession (late delivery)Developer (Seller)Liquidated damages at 10% p.a. on all instalments paid, calculated daily from due VP date until actual VP delivered. Deductible from outstanding purchase price.
Failure to pay instalments (buyer default after S&P)BuyerDeveloper may forfeit 20% of purchase price and repossess the unit. Buyer loses the unit and all payments up to the 20% cap.
Unauthorised alteration to premisesBuyerBuyer cannot make structural alterations without developer's written consent. If done, developer may require reinstatement at buyer's cost.
Exam tip: Liquidated damages for late VP = 10% p.a. on instalments paid (daily). Buyer default forfeiture = 20% of purchase price.

4.1eTOP, CSC & Defects Liability

ItemTOPCSC
Issued byCommissioner of Building Control (BCA)Commissioner of Building Control (BCA)
MeaningBuilding safe to occupy; minor works may be outstandingALL building works fully completed
EffectDeveloper issues Notice of Vacant Possession → keys handoverDeveloper issues Notice of Legal Completion → final payment due
Payment triggered25% of purchase price15% of purchase price
Defects Liability PeriodStarts from date of VP notice (typically 12 months)

4.1fABSD Remission for Housing Developers

When a licensed housing developer purchases residential land, they pay 40% ABSD upfront (the developer-specific rate, wef 16 Dec 2021; separate from the general 65% entity rate which applies from 27 Apr 2023). Of this, 5% is non-remittable (always payable upfront within 14 days of acquisition). The remaining 35% may be remitted upfront if all sale conditions are met (sell ALL units within 5 years from land acquisition).

Total Developer ABSD

40%

Paid upfront on residential land purchase. Licensed housing developers only.

Non-Remittable

5%

Always payable. Cannot be waived regardless of conditions met.

Remittable (Condition)

35%

Remitted only if ALL residential units are sold within 5 years from land purchase.

Penalty for breach: If the developer fails to sell ALL units within 5 years, the remitted ABSD (minus the non-remittable 5%) is clawed back in full plus interest.

4.1gExecutive Condominiums (EC)

ECs are a hybrid public-private housing type — built by private developers but governed by HDB-like restrictions initially. They are sandwiched between HDB flats and fully private condominiums.

Buyer eligibility (purchase from developer):

  • • At least 1 Singapore Citizen in the family nucleus
  • • Must form a qualifying family nucleus (married, fiancé/fiancée, etc.)
  • • Household income ceiling: $16,000/month (gross)
  • • Cannot own other property locally or abroad at time of purchase
Timeline from TOPWho can buy on open market?
Within 5 years (MOP)Cannot sell on open market (only HDB/developer in special cases)
After 5 yearsSingapore Citizens and PRs only
After 10 years (fully privatised)Anyone — including foreigners

4.1hQualifying Certificate (QC) — Foreign-Owned Developers

Developers who have non-Singapore shareholders or directors must obtain a Qualifying Certificate (QC) from the Land Dealings (Approval) Unit before purchasing residential land. QC imposes strict completion and sale conditions.

QC ConditionRequirement
Obtain TOPMust obtain Temporary Occupation Permit (TOP) within 5 years from land purchase
Sell all unitsMust sell ALL residential units within 2 years of obtaining TOP
Extension chargesCharged pro-rata on unsold units if deadline not met (see below)
SGX-listed exemptionSGX-listed developers with a 'substantial Singapore connection' may be exempt (wef 6 Feb 2020)

QC Extension Charges (on unsold units, pro-rated)

Year 1

8%

p.a.

Year 2

16%

p.a.

Year 3+

24%

p.a.

Charges are pro-rated on the number of unsold units. Designed to prevent developers from sitting on unsold stock.

4.1iSub-Sale — Selling an Uncompleted Unit

A sub-saleoccurs when buyer "A" sells the uncompleted unit to buyer "B" after signing the S&P with the developer, but before legal completion.

StepAction
1A pays option fee (5%) to developer and gets OTP
2A signs S&P with developer (OTP exercised)
3A pays BSD within 14 days
4A decides to sub-sell to B — must inform developer
5B's lawyers write to developer to request new S&P
6Developer prepares new S&P agreement with B on same terms
7B signs S&P and becomes the new owner

RES Obligations in a Sub-Sale

  • Advise A that Seller's Stamp Duty (SSD) applies to the sub-sale
  • Prepare OTP for A to B — must include the standard sub-sale clause
  • B bears administrative and legal costs charged by developer for new S&P

Standard Sub-Sale Clause (OTP from A to B):

“The Vendor shall endeavour to procure the Developer's agreement to a novation of contract with the Purchaser but in any event the Vendor shall execute the usual subsale Deed of Assignment-cum-Power of Attorney in the Purchaser's favour. The Purchaser shall bear the administrative and legal costs charged by the Developer for the issuance of any fresh Sale and Purchase Agreement. The Vendor shall authorise and direct the Developer to credit all monies paid by the Vendor in satisfaction of the sale price to the Purchaser's account.”

4.1jSCPA vs HDCLA — Commercial vs Residential Uncompleted Properties

The Sale of Commercial Properties Act 1979 (SCPA) governs uncompleted commercial properties. Compare it with HDCLA (residential):

AspectHDCLA (Residential)SCPA (Commercial)
Option FeeMin 5%, max 10% of purchase priceNo minimum stated; cannot exceed 10%
Refund if Option Not Exercised75% of option fee refunded50% of option fee refunded
Developer LicenceMandatory — must obtain Sale or No-Sale LicenceNot required — can sell after Building Plan Approval from Commissioner of Building Control
Project AccountMandatory for developers with Sale LicenceNot mandated (but most developers maintain one voluntarily)
Advertisement ControlsHousing Developers Rules regulate advertisementsNo equivalent rules for commercial properties
Standard OTP/S&PCEA prescribed standard forms requiredNo prescribed standard forms
Exam tip: SCPA gives less buyer protection than HDCLA — no mandatory licence, no prescribed forms, only 50% refund on unexercised option. Commercial buyers should do more due diligence.
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Section Quiz

4.1 — New Launch & Uncompleted Properties

10 questions · 90 seconds each · exam-style difficulty

Rules: Time runs out → question is marked wrong. Read carefully — options are designed to trap you.