LicenseCompare

Securities and Futures Commission

Hong Kong SFC Type 9 asset management application pack

A practical evidence pack map for Hong Kong Type 9 asset management licensed corporation, responsible officer, licensed representative, investment process, custody, and financial resources applications.

Route focus

SFC Type 9 is usually the route for asset management, discretionary portfolio management, fund management, and managed account activity. The pack should prove the actual investment workflow, the people who control it, and the controls around client assets, valuation, conflicts, dealing, and reporting.

Who this helps

  • - Startup fund managers preparing a first SFC Type 9 corporation application
  • - Family offices or private fund managers checking whether external-client activity changes the route
  • - Existing licensed corporations adding Type 9 or changing the investment management model
  • - Responsible officer candidates who need to turn experience into activity-specific evidence

Licence scope

  • - Decide whether the workflow is pure Type 9 asset management or also includes Type 1 dealing, Type 4 advice, fund marketing, custody, or Type 6 corporate finance activity.
  • - Identify whether the firm will manage private funds, managed accounts, discretionary mandates, REIT-related portfolios, or internal group assets.
  • - Map professional investor limits, public marketing, cross-border delegation, sub-advisory, research, dealing, valuation, and custody assumptions.
  • - Check whether any responsible officer licence condition, non-sole condition, or REIT management accreditation issue changes launch planning.

Pre-draft questions

  • - Which legal entity signs mandates and makes investment decisions?
  • - Who has final portfolio authority, and which responsible officer supervises that authority day to day?
  • - Will the firm place trades itself, instruct brokers, or rely on a group affiliate or delegated manager?
  • - Where are fund assets or client assets held, who can instruct movement, and how are fees deducted?
  • - Does the business plan match the financial resources calculation, staffing plan, compliance manual, and internal control questionnaire?

Evidence pack

Investment model

  • - Mandate map covering funds, managed accounts, discretionary authority, investment committee, research, trade approval, and valuation.
  • - Product and strategy notes that explain liquidity, leverage, derivatives, side pockets, private assets, valuation, and redemption assumptions where relevant.
  • - Broker, custodian, administrator, auditor, fund counsel, and outsourced-provider map with oversight owners.

Controls and policies

  • - Compliance manual tied to actual Type 9 workflows: onboarding, professional investor checks, suitability where relevant, conflicts, personal account dealing, best execution/dealing allocation, complaints, and recordkeeping.
  • - AML/CFT framework, sanctions screening, source-of-funds handling, investor due diligence, and ongoing monitoring.
  • - Custody and client asset memo explaining whether the firm holds, controls, instructs, or only oversees third-party custody.

Financial and operating evidence

  • - Financial resources calculation, bank evidence, forecast, budget, capital runway, professional indemnity or insurance assumptions where applicable.
  • - Organisation chart, MIC map, board approvals, substantial shareholder information, premises, technology controls, outsourcing register, and business continuity plan.
  • - Launch checklist that reconciles the application narrative with client agreements, offering documents, marketing decks, and public register expectations.

People and governance

  • - Nominate at least two responsible officers for Type 9 and show authority, availability, competence, and activity-specific experience.
  • - Separate responsible officer evidence from licensed representative evidence; not every portfolio person automatically proves RO readiness.
  • - Connect MICs, executive directors, investment committee members, compliance, AML/CFT, operations, and valuation owners to the same operating model.
  • - If REIT management, complex products, or overseas experience is material, prepare a targeted explanation rather than assuming generic asset management experience is enough.

Forms and submission

  • - New corporation applications normally begin with SFC corporation application materials, individual responsible officer/licensed representative materials, supplements, questionnaires, and fee evidence.
  • - Submit relevant applications through WINGS-LIC and keep source documents ready for SFC follow-up.
  • - Before launch, confirm the public register record, responsible officers, licensed representatives, regulated activity scope, and any conditions.

Timeline risks

  • - Responsible officer competence, local availability, and authority are often the slowest issues.
  • - Weak custody, valuation, outsourcing, conflicts, or trade allocation evidence can create follow-up rounds.
  • - A Type 9 application that quietly contains Type 1 dealing, Type 4 advice, or fund marketing often needs route correction before it is adviser-ready.

Questions to ask advisers

  • - Does this client journey trigger Type 1 or Type 4 alongside Type 9?
  • - Can each proposed responsible officer supervise the regulated activity in substance?
  • - Are the financial resources, custody model, and business plan consistent with the requested licence scope?
  • - Which documents should be changed before submission because they contradict the application narrative?

Common mistakes

  • - Using a fund pitch deck as a substitute for an operating-control business plan.
  • - Listing senior investment staff without proving responsible officer authority and supervision.
  • - Ignoring custody control because a third-party custodian is appointed.
  • - Treating professional-investor-only distribution as removing all marketing, suitability, and onboarding controls.

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.