Focused comparison
Hong Kong custody/client assets vs United Kingdom custody/client assets
A focused comparison for custody/client assets businesses choosing between Hong Kong and United Kingdom.
| Question | Hong Kong | United Kingdom |
|---|---|---|
| Likely route | SFC client asset, custody, Type 1, and financial resources analysis | FCA safeguarding, custody, CASS, arranging custody, and prudential analysis |
| Key people | Licensed representatives for regulated functions At least two responsible officers for each regulated activity | Senior Manager Function approval where a controlled function applies Certification for relevant staff under SM&CR where applicable |
| 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 prudential requirements depend on the permissions, MiFID/MIFIDPRU status, client asset position, and business model. |
| Timeline | Typically 4 to 8+ months after a serious application pack is ready. | FCA service standards distinguish complete and incomplete applications; practical timelines often run 4 to 10+ months. |
| Common bottlenecks | Responsible officers without enough authority, availability, local experience, or activity-specific competence Business plans that do not match the regulated activities requested | Permissions requested do not match the actual operating model Financial forecasts are inconsistent with the applicant legal entity or prudential category |