Focused comparison
Hong Kong custody/client assets vs Singapore custody/client assets
A focused comparison for custody/client assets businesses choosing between Hong Kong and Singapore.
| Question | Hong Kong | Singapore |
|---|---|---|
| Likely route | SFC client asset, custody, Type 1, and financial resources analysis | CMS custodial services and client asset safeguarding analysis |
| Key people | Licensed representatives for regulated functions At least two responsible officers for each regulated activity | Appointed representatives for regulated activities conducted on behalf of CMS licensees or exempt financial institutions Fit and proper assessment for directors, representatives, substantial shareholders, and key persons |
| Corporate evidence | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers |
| Capital/resources | Capital and liquid capital expectations depend on regulated activity, whether client assets are held, and other SFC financial resources requirements. | Capital and financial resource expectations depend on activity, client type, custody, and the specific licence or exemption path. |
| Timeline | Typically 4 to 8+ months after a serious application pack is ready. | Typically 4 to 9+ months depending on route and readiness. |
| Common bottlenecks | Responsible officers without enough authority, availability, local experience, or activity-specific competence Business plans that do not match the regulated activities requested | Assuming accredited or institutional clients remove all licensing questions Weak explanation of investment strategy, risk management, or outsourced functions |