Hong Kong SFC No. 9 (asset Management)business scope and core values
according toHong Kong Securities and Futures Ordinance (SFO)，Holds Hong Kong SFC No. 9 license (asset Management)institutions are authorized to provide asset management services，At its core lies ownership of the client's investment portfolioInvestment decision or discretion。This license is the most core license in the asset management field in Hong Kong，Its main business areas include：
- Traditional asset management：Allow institutions to set up and manage investment funds (such as public funds) for clients on a discretionary basis、private equity funds、hedge fund、PE/VC funds, etc.)，and manage clients’ investment portfolios or special accounts。
- Virtual Asset (VA) Management：Suitable for virtual asset fund management、Crypto Portfolio Investment、Tokenized asset trust management and other services。Any virtual assets with security properties (such as STO、Cryptoasset structured products, etc.) for management and allocation，All belong to the category of No. 9 plate。
Obtaining this license will not only enhance the institution’s、Credibility among custodians and investors，It also legally expands cross-border asset management business.、An important basis for realizing asset securitization and enjoying Hong Kong’s preferential tax policies。Port communicationsuggestion，Institutions can also apply for license No. 1 (for securities trading) or license No. 4 (for providing advice on securities).，Forming an integrated financial service closed loop of "raising/distribution/investment consulting/management/transaction execution"。
Chinese companies apply for No. 9 license - industry cases
In recent years, more and more institutions from mainland China and Chinese background have accelerated their overseas expansion，Actively applyHong Kong Securities and Futures Commission (SFC) License No. 9 (Asset Management License)。According to the latest data，The number of licensed and existing private equity institutions with mainland background has exceeded 100。
The following are the main types of applicant institutions、Company list、Background characteristics and application purpose：
one、 Head and tens of billions of private equity institutions (core main force) Such institutions are currently the backbone of cross-border licensing，Mainly covers subjective private placement、Quantitative private equity and “subjective + quantitative” hybrid private equity。in，Ten billion-level and nearly tens-billion-level private equity accounts for nearly 50%。
- Represent the company：
- Established/Early Licensed Private Equity： Jinglin Assets(Licensed in 2005)、freshwater spring(Licensed in 2011)、Infore Capital (licensed in 2014)、Yuanfeng Fund, etc.。
- Tens of billions of private placements approved in recent years： CEIBS、Jiukun Investment、Mingshi Fund、Tianyan Capital、evolution assets、Panze Assets、Good times private placement、Shanghai Dapu Assets、Inno Assets、Dunhe Asset Management、Renqiao Assets、Jin Ge Liangrui、Qianxiang Assets、Hesheng Assets、Century Frontier、Quantitative investment、sum of squares investing、Zhicheng Zhuoyuan、Blackwing Assets etc.。
- Small and medium-sized private placement： Youli Investment、Qianhai Bopu Assets、Hongshang Assets、Longhang Assets、Qingbai Assets、Yongxin International Investment、Xinshan Investment, etc.。
- background features： They usually have strong domestic financial strength、An asset management institution with a large management scale and a mature investment research system。Because cross-border layout requires extremely high compliance construction、Initial costs such as overseas team formation, etc.，These leading institutions with long-term operational compliance advantages are more likely to pass regulatory review and absorb upfront investments.。
two、 Hong Kong subsidiaries of leading and medium and large securities firms With the globalization of wealth management and the explosion of demand for cross-border private equity custody,，Chinese securities companies are also intensively laying out the Hong Kong license matrix through capital increase and other methods (usually holding 1、4、6、9license plate combination)。
- Represent the company： CITIC Securities、CICC、China Merchants Securities、Cathay Pacific Haitong、GF Securities、Huatai Securities、Soochow Securities、Shanxi Securities、Huafu Securities, etc.。
- background features： As the core hub of the mainland’s financial system，They have an extremely large domestic high net worth and institutional client base。Currently moving from a single domestic market to "domestic and overseas integration"，Provide one-stop cross-border custody and wealth management closed-loop services for Chinese private equity “going out” and overseas capital “bringing in”。
three、 The core purpose of applying for No. 9 license
- Diversify geographical risks，Broaden strategic boundaries： Overseas markets cover diversified asset targets and abundant financial instruments。Obtaining the No. 9 license can help institutions implement global multi-asset strategies overseas，Reduce portfolio dependence on a single economy，Improve the overall configuration’s resistance to volatility and differentiated income space。
- Meet the global allocation needs of high net worth and institutional clients： Leading private equity and securities firms have long served institutional investors and high-net-worth individuals，The demand for global asset allocation among these customer groups continues to grow.。Holding a Hong Kong license can force organizations to improve their cross-border service capabilities，Meet customer needs and significantly enhance customer stickiness。
- Break through the ceiling of local competition，Achieve global transformation： Competition in the domestic asset management industry is increasingly fierce，Exploring overseas markets is an inevitable strategic choice for institutions to explore new growth curves.。Through global layout，Chinese-funded institutions can enhance international brand influence，Transformation into a truly global asset management organization。
- Laying out specific frontier areas (such as technology companies)： Some technology giants (such as ByteDance) applied for this license across borders，Mainly to take advantage of Hong Kong’s market environment，Focus on and deploy asset management business in the fields of technology and artificial intelligence (AI) on a global scale。
Four、 Hong Kong’s capital market，At the same time attract internationally renowned private equity companies：
Hong Kong SFC No. 9 (asset Management)capital and site conditions
This is the most common form in the industry and is easier to pass.。Institutions do not directly handle client funds，Client assets are held by independent third-party custodians or brokers。This type of license has no minimum paid-up share capital requirement (i.e. 0 Hong Kong dollars)，However, a minimum liquid capital of at least HK$100,000 must be maintained in accordance with the Financial Resources Rules (FRR)。In practice，Hong Kong Xintong recommends that the daily margin reserve be maintained at more than HK$1 million。
Allow institutions to directly hold or control client assets，Suitable for large-scale operations such as issuing public offerings，However, it faces extremely high internal control and audit requirements。The minimum paid-up share capital requirement for this type of license is HK$5 million，Minimum liquid capital needs to be maintained at HKD 3 million。In actual operation，Margin requirements usually need to be maintained at a minimum of HK$4.5 million。
The applicant must be a limited company registered in Hong Kong or a non-Hong Kong company that has completed overseas company registration。Must have an actual commercial office address in Hong Kong (usually required to be a Grade A commercial building)，Absolutely no co-working spaces or virtual secretary addresses are allowed。also，It is necessary to establish a complete physical isolation mechanism for access control and files。
Hong Kong SFC No. 9 (asset Management)Qualification requirements for RO responsible persons
Licensed institutions are required to have at least 2 qualified responsible officers (ROs) for each regulated activity to supervise the business.。in，At least one must be the company’s executive director (Executive Director)，and must have sufficient management authority over their business。SFC requires at least 1 RO to be resident in Hong Kong，To achieve effective supervision anytime and anywhere。
The proposed RO must have at least 3 years of experience in asset management within the past 6 years、Industry experience directly related to financial investment。The SFC may also recognize discretionary account management at its discretion、Private equity or proprietary trading experience。also，Applicants must have at least 2 years of proven management skills and experience supervising people。
RO must be proficient in the Securities and Futures Ordinance (SFO) and AML regulations。Usually you need to pass a recognized qualification examination (such as Paper) organized by the Hong Kong Securities and Investment Institute (HKSI) 1, 6, 7, 9, 12and other combinations)。If you have equivalent overseas regulatory experience，Can apply to SFC for conditional exemption，However, additional continuing professional training (CPT) is required。
ROs must meet the SFC’s strict “Fit and Proper” requirements。Must be in good financial standing (no bankruptcy record)，and good reputation and character.。There must be no record of major financial violations、Criminal record or disciplinary action by other regulatory agencies。Major shareholders (UBO) also need to pass source of wealth (SoW) review。
Hong Kong SFC No. 9 (asset Management)application process
Hong Kong Xintong helps customers clarify their business models，Define whether to hold client assets (big 9-number card vs small 9-number card)，Whether virtual assets are involved (VA Uplift)，And complete the Hong Kong company registration accordingly、Leasing physical office space and preparation for capital injection。
Recruit or appoint at least 2 qualified ROs，Establish a Core Function Manager (MIC) system (covering risk management、Compliance、IT、AML and other 8 major functions)，And complete preparations for the capital source and character review of the major shareholder (UBO)。
Hong Kong Xintong's legal team drafts core delivery documents，Includes detailed business plan (Business Plan)、Compliance and Internal Controls Manual、AML/KYC Policy、Valuation mechanism、Business Continuity Plan (BCP) and IT Data Compliance Commitment。
Submit the Form online through SFC’s “WINGS” electronic licensing platform 1、Form 5/6/7 and other forms and pay the official fee。Responding to the SFC’s months-long preliminary review and multiple rounds of written inquiries (RFIs)，Clarify business model and risk control details。
After obtaining SFC "Approval in Principle (AIP)"，Satisfy conditions such as funds in place and bank account opening within 3 months in exchange for a formal license。After obtaining the license，Hong Kong Xintong can assist in completing monthly/semi-annual FRR financial declarations、Continuous compliance obligations such as regular audits and CPT training。
Hong Kong SFC No. 9 (asset Management)Official fee breakdown for
The official fee for applying for Hong Kong Securities and Futures Commission (SFC) No. 9 license is strictly charged for each regulated activity。All fees must be paid online via SFC’s “WINGS” system。The following are the official fee standards charged by SFC：
| Apply for a project | Official application fee (Hong Kong dollar) | Annual fee for subsequent years (Hong Kong dollar) |
|---|---|---|
| Licensed Corporation Application Fee (Institutional body) | $4,740 | $4,740 / Year |
| Approved as responsible person (RO) | $2,950 / per person | $2,950 / per person / Year |
| Approved as a licensed representative (LR) | $1,790 / per person | $1,790 / per person / Year |
Note：The above are only the administrative fees officially charged by SFC.。In the actual implementation process，Institutions also need to be responsible for building compliance systems、Legal consulting、RO firewood equipment、High operating costs such as leasing and auditing of Grade A office buildings。Port communicationCan provide you with an accurate overall implementation budget assessment。
Hong Kong SFC No. 9 (asset Management)Frequently Asked Questions(FAQ)
The Hong Kong Securities and Futures Commission’s Type 9 regulated activity license is the “Provision of Asset Management” license。Its core feature lies in the institution's investment portfolio (such as securities、futures contract、Investment funds, etc.) have the right or discretion to make investment decisions。The business scope covers discretionary public/private fund management、Special account financial management，and fund management involving securities-like virtual assets.。
Absolutely not。SFC strictly requires that the applicant must have an actual physical office address in Hong Kong (usually a Grade A commercial building is recommended)，And must have independent access control and file storage space。The use of co-working spaces or virtual secretary addresses is strictly prohibited。
The difference lies in whether client assets are held。There is no minimum paid-in capital requirement for Xiao 9hao Plate (which does not hold client assets)，However, liquid capital of HK$100,000 is required；Big 9 license plate (holding client assets) requires a minimum paid-in capital of HK$5 million.，And the liquid capital needs to be maintained at more than HKD 3 million。
Licensed institutions must appoint at least 2 qualified responsible officers (ROs) for each regulated activity to oversee the business。At least 1 of them must be the executive director (ED) of the company。also，SFC requires at least 1 RO to be resident in Hong Kong，To ensure effective supervision of the business anytime and anywhere。
The RO must be a "fit and proper person" recognized by the SFC。Core hard conditions include：Have at least 3 years of relevant asset management industry experience in the past 6 years；Have at least 2 years of proven management skills and experience；Pass the relevant local regulatory framework and industry qualification examinations of HKSI (unless exempted)；and no record of bankruptcy or major financial irregularities。
SFC officially promises that the processing time for corporate licensing is 15 weeks。But in practice，Taking into account multiple rounds of written inquiries (RFI) in the early stage、Supplementary materials and business complexity，The overall licensing process usually takes 6 to 8 months。
It depends on the situation。If you only manage virtual assets with securities properties (such as STO)，Belongs to the traditional No. 9 plate category。However, if the proportion of non-security virtual assets (such as pure Bitcoin positions) in the investment portfolio exceeds 10%，Institutions must apply for "VA Uplift" from SFC，And meet the extremely stringent cold wallet custody and smart contract audit requirements。
The MIC system implemented by the SFC requires licensed corporations to appoint full-time executives to be responsible for 8 core functions：Overall management supervision、Main business、risk management、Compliance、finance、IT、AML and operational control。The MIC responsible for “overall management oversight” and “principal operations” must generally also be the RO of the institution。
Institutions can outsource fund administration、IT operation and maintenance and other middle and back-end functions，However, the final power of investment decision-making must not be、"Out-of-control outsourcing" of key risk control decisions and major incident handling。For outsourced functions，Licensed corporations must conduct due diligence、Retain the right of ongoing supervision，and bear ultimate legal responsibility to regulators and customers。
If a single office only serves a single family、Manage family trust assets，Not providing asset management services to external parties、No charges to third parties and no solicitation from the public，Usually no license is required。However, if asset management services are provided to external parties、Charge management fees or actively promote，will trigger the licensing requirement for No. 9.。
Won't。If the application is withdrawn before SFC approval or rejection，Official application fees paid will not be refunded。Common reasons for rejection or delay include insufficient evidence of RO experience、Unclear business boundaries、Weak AML framework and proven insufficient source of funds (SoW) from major shareholders。
Must strictly declare。According to the Securities and Futures Ordinance，Directors of licensed corporations、major shareholder、MIC、Changes to bank account and other information，SFC must be notified via the system within 7 business days.。If you change your business address，Notice must be given at least 7 business days before the proposed change and application for approval of new premises must be made。
To form a business closed loop，The most popular “1/4/9” license plate combination in the industry。Paired with License No. 4 (advising on securities), investment advice can be legally provided；With the No. 1 license (securities trading), you can directly execute transactions or distribute fund products for customers.。If you are involved in corporate finance，Can also be stacked with No. 6 cards。
Hong Kong Information Communication-Successful Cases
