Cloud Computing industry is well developed in Singapore, so it is not a big surprise seeing MAS TRM guideline has a section only on Cloud Computing. Reading the document as whole, it seems MAS is accepting the fact that cloud computing is or will be part of financial industry development.

Section 5.2 Cloud Computing is group under a bigger topic which is IT Outsourcing. For banks, the uses of third party computing resources is indeed a form of outsourcing. Operationally and legally the relationship between banks and cloud services providers is not much different. 

From the text “Outsourcing can involve the provision of IT capabilities and facilities by a single third party or multiple vendors located in Singapore or abroad.” One can assume that outsourcing to overseas cloud computing is possible. The statement does not restrict Singapore data from being stored or processed abroad. This is important as most international organisation is hosting their application centrally in regional hubs. However, it does have some catches.

The TRM guideline (5.2.3 and 5.2.4) does not discuss much of the technical side of Cloud Computing, rather it stress on the importance on data governance, which include data segregation and removal of data on exit. I believe this is due to the enforcement of banking secrecy principle (more details are available on MAS website

In cloud computing setup, deleting all information related to one entity is tricky and costly. It would be possible for IaaS deployment where the data are stored in disk images. For SaaS or other data services, to identify each data owned by the exiting entity will be a daunting task ! The data schema must be able to cater for this unique requirement. Unless it is considered when the cloud service provider is developing the system, the cost to manual deleting data is going to escalate.