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Hong Kong Securities and Futures Commission (SFC)
The specific acceptance units and authorities shall be subject to the latest public information of the Hong Kong Securities and Futures Commission (SFC).。
1. Hong Kong No. 9 license application：Institutional background and legal basis
Type 9 regulated activities in Hong Kong are based on the Securities and Futures Ordinance (Chapter 571)，The core is to manage a portfolio of securities or futures contracts for others，and managing real estate investment plans.。Administrative only、Valuations or general commercial advice do not necessarily constitute Category 9 activities；Whether a license is required depends on the investment decision、Authorization scope and actual services。
The applicant corporation must be established in Hong Kong，Or register a non-Hong Kong company with business qualifications in Hong Kong。Each regulated activity generally appoints at least two responsible officers，At least one of them shall be an executive director，and must ensure that a responsible person is available to oversee the business at all times。represent、Responsibilities of responsible personnel and core functional managers should be consistent with the organizational structure。
Important tips：Should be based on client assets、Whether investment authority and product judgment still require the 1st、Category 4 and other licenses。
2. Core regulatory information
regulatory path
Type 9 regulated activity：Provide asset management
Should be based on client assets、Whether investment authority and product judgment still require the 1st、Category 4 and other licenses。
Check the key points
License Scope and Ongoing Obligations
The content has been combined with the disclosure rules of regulatory agencies、Cross-check application material structure and actual business process。
3. Business scope and license boundaries
Scope description
The following content is used to delineate the scope of projects for Hong Kong No. 9 license application；The final decision should be based on actual business and official approval.。
Manage a portfolio of securities or futures
Application documents should describe the products for managing securities or futures portfolios、client、channel、transaction process、Revenue model and controls。
Fund Management and Discretionary Accounts
Application documents should describe fund management and discretionary account products、client、channel、transaction process、Revenue model and controls。
Incidental activities subject to approval
Application documents should describe products with incidental activities subject to approval conditions、client、channel、transaction process、Revenue model and controls。
4. Application subject、capital、people and places
Check before applying
The Hong Kong Securities and Futures Commission (SFC) usually obtains、personnel、Review of business authenticity and risk control；Material depth will vary from project to project。
official information：Hong Kong Securities and Futures Commission (SFC)。The latest form should be double-checked before submission.、cost、Timeframes and technical requirements。
business plan
An itemized description of the proposed managed securities or futures investment portfolio、Fund Management and Discretionary Accounts、Incidental activities subject to approval，including customers、area、channel、Products and funding flows。
Equity and Management
Disclosure Shareholders、ultimate controller、Directors and key personnel，and be prepared to be honest、Proof of experience and financial resources。
Governance and Control
Establish division of responsibilities、conflict of interest、complaint、outsourcing、business continuity、Cybersecurity and financial controls。
AML/CFT Framework
Establish customer due diligence based on risk assessment、Continuous monitoring、Sanctions Screening、suspicious transaction report、Record keeping and training mechanisms。
Capital and financial resources
If the license is subject to a condition not to hold client assets，Class 9 generally has no minimum paid-up share capital requirement，Minimum liquid capital is HKD100,000；If allowed to hold client assets，The minimum paid-up share capital is HK$5 million，Minimum liquid capital is HKD 3 million。It still needs to be reviewed according to the latest financial resources rules before submission.。
Key People and Governance
The applicant must assign at least two responsible persons for Category 9 activities，At least one of them shall be an executive director，and ensure that at least one responsible person is available to oversee the business at all times。RO’s Industry Experience、Management experience、Examination or exemption and arrangements for performance of duties in Hong Kong must be explained on a person-by-person basis。
Office and local content
office、Registered address and record keeping location should be checked separately。If the regulatory authority requires local substance，A mail-only virtual address must not be used as a substitute for actual management、customer service、System control and file access arrangements。
5. Government charges and project budgets
The budget should differentiate between statutory expenses、Capital or margin、Company and premises costs、Personnel costs and professional service fees。If there is no official basis, do not write a fixed total price or guarantee the betting period.。
| budget items | Billing basis | Checkpoints |
|---|---|---|
| Regulatory application and annual fees | By license type、Scope of authority、Number of applicants and key personnel，and calculation of the current fee schedule of the competent authority.。 | Only quote the current fee schedule of the competent authority；Third-party service fees must not be packaged as government fees。 |
| capital、Security deposit and insurance | If the license is subject to a condition not to hold client assets，Class 9 generally has no minimum paid-up share capital requirement，Minimum liquid capital is HKD100,000；If allowed to hold client assets，The minimum paid-up share capital is HK$5 million，Minimum liquid capital is HKD 3 million。It still needs to be reviewed according to the latest financial resources rules before submission.。 | Capital is not a service fee，Nor shall it be satisfied by temporary borrowings or funds from unexplained sources.。 |
| Company establishment and statutory maintenance | According to registration place、share capital、registered agent、secretary、Registered address、Separate quotations for annual reports and tax returns。 | The establishment of a company does not mean the approval of a license or the opening of a bank account.。 |
| Office and personnel | by lease、deposit、area、use、local salary、Visa and residency requirement accounting。 | First confirm the substantive requirements for regulatory acceptance，Sign a new lease or hire staff。 |
| system、Systems and professional services | AML/KYC calculation based on business complexity、Sanctions Screening、Transaction monitoring、network security、audit、legal advice、Translation and notarization。 | The quotation should specify the scope、hypothesis、Third-party fees and number of replacement parts。 |
6. Application process and review cycle
The length of the process depends on the complexity of the business、Data completeness and inquiries from the Hong Kong Securities and Futures Commission (SFC) or receiving agencies，It is not appropriate to promise a fixed time for approval。
first step：Delineate regulated activities
put product、client、area、Channels and fund flows are mapped to Category 9 regulated activities：Provide license scope for asset management。
Step 2：Design subject and governance structure
Determine the applicant、Equity、director、key personnel、Office space and outsourcing arrangements。
Step 3：Prepare application and institutional documents
Prepare business plan、financial forecast、Organizational structure、Risk assessment and various compliance policies。
Step 4：Submit and receive review
Submit an application to the Hong Kong Securities and Futures Commission (SFC)，Reply to addendum、Interview、System demonstration or on-site inspection。
Step 5：Approval and continued compliance
Check license conditions，Complete capital before starting business、personnel、system、Client assets and reporting arrangements。
7. Licensed、Renewal and ongoing supervision
Capital requirements depend on permission to hold client assets：Category 9 corporations that do not hold client assets generally do not have minimum paid-up share capital requirements，However, a minimum liquid capital of not less than HK$100,000 must be maintained；When permitted to hold client assets，Normally required to maintain paid-up share capital of HK$5 million and liquid capital of HK$3 million，And calculated continuously according to financial resource rules。
8. 2023–2026 Regulatory Updates and Official Information
The current SFC Licensing Manual should be used before submission in 2026、Competency Guidance、Continuing Professional Training Guidelines and Financial Resources Rules，Check the industry experience of the responsible person、Exam exemption、External management functions and licensing conditions。The so-called "affiliated responsible personnel" cannot replace real management and continuous supervision.。
Official verification entrance：Hong Kong Securities and Futures Commission：Intermediary Licensing and Type 9 Regulated Activities。
Information update instructions：regulatory scope、capital、personnel、cost、Time limits and continuing obligations subject to adjustment，Before formal application, the current rules of the competent authority should be followed、The form and case approval shall prevail.。
9. Customer FAQ
Type 9 regulated activities in Hong Kong are based on the Securities and Futures Ordinance (Chapter 571)，The core is to manage a portfolio of securities or futures contracts for others，and managing real estate investment plans.。Administrative only、Valuations or general commercial advice do not necessarily constitute Category 9 activities；Whether a license is required depends on the investment decision、Authorization scope and actual services。 The applicant corporation must be established in Hong Kong，Or register a non-Hong Kong company with business qualifications in Hong Kong。Each regulated activity generally appoints at least two responsible officers，At least one of them shall be an executive director，and must ensure that a responsible person is available to oversee the business at all times。represent、Responsibilities of responsible personnel and core functional managers should be consistent with the organizational structure。
Application documents should describe investment strategy、Customer Category、Carte blanche authority、Valuation、best execution、soft commission、conflict of interest、personal trading、outsourcing、Client assets and fund structure。If the license condition is not to hold client assets，bank、hosting、Payment authorization and system permissions must also demonstrate that there will not be actual takeover of customer assets。
Capital requirements depend on permission to hold client assets：Category 9 corporations that do not hold client assets generally do not have minimum paid-up share capital requirements，However, a minimum liquid capital of not less than HK$100,000 must be maintained；When permitted to hold client assets，Normally required to maintain paid-up share capital of HK$5 million and liquid capital of HK$3 million，And calculated continuously according to financial resource rules。
The current SFC Licensing Manual should be used before submission in 2026、Competency Guidance、Continuing Professional Training Guidelines and Financial Resources Rules，Check the industry experience of the responsible person、Exam exemption、External management functions and licensing conditions。The so-called "affiliated responsible personnel" cannot replace real management and continuous supervision.。 See the latest rulesHong Kong Securities and Futures Commission：Intermediary Licensing and Type 9 Regulated Activities。
The system should be based on the company's customers、Country or region、product、Channel and transaction characteristics shape enterprise risk assessment，and fall to customer due diligence、Beneficial owner identification、Continuous monitoring、Sanctions and PEP Screening、Suspicious transaction escalation and reporting、record keeping、Staff training and independent testing。Directly apply common templates、There is no threshold basis or the operation record cannot be displayed，Usually insufficient to prove that the system can actually operate。
Don’t judge based on just a single number。Legal minimum capital should be distinguished、regulatory capital、margin、Insurance、Protection of customer assets and sufficient financial resources to sustain operations，And check the current rules of the Hong Kong Securities and Futures Commission (SFC) according to the scope of application and business scale。Source of funds、Financial forecasts and stress scenarios should also be interpretable and verifiable。Special attention should also be paid to this project：Should be based on client assets、Whether investment authority and product judgment still require the 1st、Category 4 and other licenses。
The answer depends on local laws、Type 9 regulated activity：Provide application qualifications for asset management、Planned activities and outsourcing model。Even if the rules do not uniformly provide for a certain position or area，Hong Kong’s Securities and Futures Commission (SFC) may still pay attention to the decision、Record、customer service、Whether risk management and regulatory communications have sufficient local substance；Before leasing space or hiring personnel，Case requirements should be checked first。
Review time is subject to application completeness、business complexity、Key personnel qualifications、Regulatory inquiries、Interviews or system demonstrations and third-party attestation of impact，It is not appropriate to promise a fixed date for approval。The project plan should separately list preparation、submit、Supplementary parts、Technical rectification and post-approval commissioning phase，and retain sufficient buffering；Only the competent authority can decide whether to accept and approve。
Usually not。Applicants should complete supplier due diligence，Describe data flow、service level、Audit right、Subcontract、information security、Business continuity and exit arrangements，and retain the rules、threshold、Alarm handling and major accident supervision capabilities。Whether outsourcing is ultimately allowed and what notification or approval is required，Should be checked in accordance with the current regulations of the Hong Kong Securities and Futures Commission (SFC)。
Already submitted、Company registration under review or completion is described as approved。Formal commencement of regulated activities、Actively solicit customers、Before collecting client funds or issuing potentially misleading licensing claims，It should be confirmed that the license has taken effect、The business does not exceed the approved scope，And also check the cross-border marketing rules of the target customer’s location。
Common matters include renewal or annual fees、Regulatory filing、Financial or compliance audit、training、record keeping、Complaint handling、Client Assets and Capital Monitoring，and equity、director、key personnel、address、Business scope、System and major incident notification or prior approval。A compliance calendar and change approval process should be established，and get regular rule updates from the Hong Kong Securities and Futures Commission (SFC)。
should beHong Kong Securities and Futures Commission (SFC)Current regulations issued、Application form、guidelines、The fee schedule and announcement shall prevail。88MSO page is used to help organize questions and materials，Not representing regulatory agencies，Nor can it replace local lawyers、Opinions from tax consultants or competent authorities on individual cases。
You can continue reading based on project boundariesHong Kong MSO Money Services License、Hong Kong VASP Virtual Asset Service License。These pages are used to compare different regulatory pathways or supporting services；Do they need to be processed at the same time?，real product、Customer area、The contracting entity and capital flow shall prevail.。
Government or competent authority fees should correspond to official fee schedules、Payment notice or receipt；capital、margin、Insurance、office、personnel、system、audit、law、Translation and consulting services are independent budget items。Formal quotations should specify the currency、taxes、third party expenses、Applicable Assumptions and Exclusions。
The applicant should be confirmed first、Legal registered address、actual management location、Differences Between Customer Reception Locations and Record Keeping Locations，Recalculation of registration fees、agent or secretary、rent、deposit、furnish、communication、Insurance、Visas and local personnel。Rent an office first and then determine regulatory boundaries，May cause unrecoverable costs。