SINGAPORE: A financial adviser devised a scheme to earn more commissions by registering policies she sold under her subordinates’ names, before asking her subordinates to transfer their commissions and bonuses to her.

She was promoted to branch director but was later demoted to a Tier 1 representative after Manulife conducted an internal investigation.

Goo Tze Ling was sentenced to eight months’ jail on Monday (Mar 30). She pleaded guilty to two counts each of forgery with intent to commit fraud and unauthorised computer access.

Another three charges were taken into consideration.

THE CASE

The court heard that Goo was a licensed financial adviser at Manulife Financial Advisers. She joined as a unit manager in March 2020 and had the designation “assistant vice president”.

She supervised a team of about five people, which grew larger over time.

Goo and her team sold investment-linked policies to their clients. Several electronic documents had to be signed by the client and the respective financial adviser or sales representative in order to complete the sale of such a policy.

The documents are completed and signed electronically via Manulife’s computer system called “Manutouch”. Each Manulife representative has an account with Manutouch, which they access with unique usernames, passwords and two-factor authentication via a One-Time Password.

The unit manager has to check and verify the completed and signed policy documents before submitting them to Manulife for processing and payment.

Manulife paid certain sales commissions and performance bonuses to its representatives if they fulfilled certain criteria. For example, if the policy is renewed for another year, a further commission is paid to the representative.

Unit managers usually earn an overriding fee which is 21 per cent of the sales commission earned by the representative in their team.

If the unit manager were to sell a policy in her own name, she would be paid a sales commission but not receive the overriding fee.

In 2020, Goo devised a scheme to earn both the sales commission for her subordinates, renewal commissions and the overriding fee for the policies she sold under her own name.

She would register the policies she sold to her clients under two of her subordinates’ names, resulting in Manulife paying her subordinates their commissions, paying Goo her overriding fee and all of them their bonuses.

Goo then instructed her subordinates to transfer their commissions and bonuses to her. She would access their Manutouch accounts and forge their signatures on the policy documents.

The two subordinates, Jimmy Ling Xiao Ting and May Oo Thin, agreed to take part as they trusted Goo and also because they could achieve their sales targets this way.

At the time, the branch director was not aware of this illegal arrangement.

CLIENT FILES COMPLAINT

In March 2022, a 64-year-old woman was introduced to Goo as she wanted to purchase an investment-linked policy.

Goo convinced her to buy two such policies. May provided her OTP to Goo on her instructions, and Goo used May’s login details to complete the sale of a five-year and a 10-year investment-linked policy for the client.

The woman, who could not read or understand English, signed the sets of policy documents, while Goo forged May’s signatures without May’s knowledge.

The policy documents were submitted to Manulife. The company later gave a total of about S$14,000 in commissions, overriding fees and bonuses to Goo, May and their branch director between 2020 and 2022 for this sale.

As instructed by Goo, May transferred her share of more than S$9,000 to Goo.

In November 2022, the client and her son filed a complaint to the Monetary Authority of Singapore after discovering that the policy documents reflected May’s name and signature, when the client had never met May.

Manulife began internal investigations. On Jan 25, 2024, a compliance officer lodged a police report on behalf of Manulife saying Goo had forged signatures on policy documents.

Manulife later offered to rescind and refund the client’s policies. She agreed in June 2023. She was refunded S$12,000 for the first policy and S$34,000 for the second – the full amount of premiums paid.

Court documents detailed other examples of how Goo forged her subordinates’ signatures for more commissions.

On Jan 1, 2023, Goo was promoted to branch director and held the designation of senior vice-president. However, after the internal investigation, she was demoted to a Tier 1 representative.

Deputy Public Prosecutor Natalie Chu said Manulife disbursed a total of S$30,627.10 in commissions, fees and bonuses to Goo, her supervisees and the branch director.

Goo received about S$27,911 from this arrangement, which was about S$6,900 more than she would have received if she had registered the policies in her own name.

Ms Chu sought eight to 12 months’ jail for Goo, saying her offences were premeditated and planned, and that she had abused her position on multiple levels.

For forgery with intent to commit fraud, an offender can be jailed for up to 10 years and fined. As her charges involved multiple instances, Goh faced up to double these penalties.

For unauthorised access to a protected computer, she could have been jailed for up to 20 years, fined up to S$100,000, or both.