Focused comparison
Hong Kong custody/client assets vs United States custody/client assets
A focused comparison for custody/client assets businesses choosing between Hong Kong and United States.
| Question | Hong Kong | United States |
|---|---|---|
| Likely route | SFC client asset, custody, Type 1, and financial resources analysis | Investment adviser custody rule, qualified custodian, broker-dealer custody, and state custody analysis |
| Key people | Licensed representatives for regulated functions At least two responsible officers for each regulated activity | Investment adviser representatives may require state registration depending on facts Broker-dealer registered representatives require firm sponsorship, CRD filing, exams, and registration |
| 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. | Adviser capital rules are usually state-specific or tied to custody and other facts; broker-dealers face SEC net capital and FINRA membership expectations. |
| Timeline | Typically 4 to 8+ months after a serious application pack is ready. | SEC adviser registration can become effective in about 45 days if complete; FINRA new member review may run up to 180 calendar days for substantially complete applications. |
| Common bottlenecks | Responsible officers without enough authority, availability, local experience, or activity-specific competence Business plans that do not match the regulated activities requested | Broker-dealer issues hidden inside compensation, solicitation, placement, or transaction workflows Custody, private fund audit, and fee deduction arrangements not fully analysed |