Hong Kong SFC Type 1/Type 4 dealing and advising application pack

Route focus

A Type 1/Type 4 application should prove the actual securities client journey: how prospects are introduced, how advice or research is given, how orders are placed or transmitted, how compensation is earned, how client assets are handled, and which responsible officers supervise each regulated activity.

Who this helps

• - Hong Kong securities brokers, introducing brokers, placement agents, and fund distributors preparing a first SFC application
• - Investment advisory, research, wealth, or platform firms deciding whether Type 4 sits alongside Type 1 or Type 9
• - Existing licensed corporations adding Type 1 or Type 4 to an asset management, corporate finance, or distribution business
• - Responsible officer and licensed representative candidates turning securities dealing or advice experience into application evidence

Licence scope

• - Map whether the business deals in securities, distributes funds, introduces securities transactions, places orders, receives transaction compensation, gives securities advice, issues research, or does several of these at once.
• - Separate Type 1 dealing, Type 4 advising, Type 9 asset management, Type 6 corporate finance, fund marketing, and custody/client asset assumptions before selecting activities.
• - Identify client types, professional investor checks, retail-facing features, cross-border marketing, websites, referral arrangements, account opening, order flow, and any client asset or settlement touchpoint.
• - Check whether the firm needs licence conditions, limitations, temporary licensing, additional regulated activities, or a variation rather than a first-time corporation application.

Pre-draft questions

• - Where does the client first receive a securities recommendation, research note, order form, subscription document, or execution/placement invitation?
• - Who receives commissions, trailer fees, placement fees, spreads, success fees, or advisory fees, and how is that disclosed and controlled?
• - Will the firm hold client money or securities, instruct a custodian, rely on an introducing broker, or only arrange through third-party settlement?
• - Which people will act as responsible officers, licensed representatives, MICs, dealing supervisors, research/advice approvers, compliance owner, AML/CFT owner, and complaints owner?
• - Do the application forms, business plan, policies, client agreements, website, marketing decks, and public-register expectations describe the same Type 1/Type 4 workflow?

Evidence pack

People and governance

• - For a new licensed corporation, plan Forms 5 and 6 around at least two responsible officer nominations for the relevant regulated activities, not only around senior titles.
• - Responsible officer evidence should prove real supervisory authority over dealing, advice, research, client onboarding, and order or distribution workflows.
• - Licensed representatives should be mapped by regulated activity, product scope, client type, and supervision owner; a broad job title is not enough.
• - If the business uses overseas desks, introducers, research providers, group brokers, or third-party custodians, document who controls the Hong Kong regulated activity and who can stop the workflow.

Forms and submission

• - Use SFC WINGS-LIC and the current application procedures page as the submission map for corporate and individual applications.
• - For a new corporation application, prepare Form 1, Forms 5 and 6 for responsible officer/licensed representative applications where relevant, Supplements 1, 2 and 3 as appropriate, questionnaires, board approval evidence, and the application fee.
• - SFC's application procedures page states normal processing times of about 15 weeks for licensed corporation applications, 10 weeks for responsible officer applications, and 8 weeks for normal licensed representative applications, subject to application quality and follow-up.
• - Before launch, verify the licensed corporation, regulated activities, responsible officers, representatives, conditions, and accreditation records on the SFC public register.

Timeline risks

• - The main delay is often route ambiguity: a pitch that says distribution, research, advice, dealing, placing, and portfolio management without deciding which SFC regulated activities are actually requested.
• - Responsible officer availability, competence, local regulatory framework evidence, and actual authority can slow the people file.
• - Client asset and settlement facts can change the evidence pack if the firm touches money, securities, custody instructions, or broker/custodian accounts.
• - Marketing decks, websites, client agreements, compensation terms, or referral arrangements that contradict the application narrative create avoidable follow-up.

Questions to ask advisers

• - Does this journey require Type 1, Type 4, Type 9, Type 6, or a combination?
• - Are order handling, execution, placing, research, advisory calls, and fund distribution controlled by the same licensed entity?
• - Can each proposed responsible officer supervise the regulated activity in substance and in Hong Kong?
• - Where do suitability, disclosure, product due diligence, professional investor, and client asset controls need to be documented before submission?

Common mistakes

• - Calling a placement, fund distribution, or broker-introduction flow mere marketing without checking Type 1 dealing triggers.
• - Using Type 4 advice language while compensation and documents show transaction-based dealing or placement activity.
• - Leaving client asset and settlement analysis to the broker or custodian instead of explaining the applicant's role.
• - Treating SFC forms as the pack rather than reconciling forms with policies, client documents, people files, and public-facing claims.

Disclaimer

Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.