Which businesses typically require SEC compliance support?
SEC compliance is usually related to "whether securities-related services are provided to U.S. investors/whether securities business activities are conducted in or to the United States."。Common trigger scenarios include：
- Investment Adviser related：Provide investment advice、Manage client assets、Charge consulting or performance fees；involvingAdvisers ActCompliance programs under (e.g. Rule 206(4)-7）。
- Broker-Dealer related：Engaged in securities transaction matching、Valet transaction、Underwriting/Distribution、Trade Execution and Clearing Arrangements；involvingExchange Actand FINRA rules (if applicable)。
- Private Equity and Fund Raising：Reg D / Reg S structure、Private Placement Memorandum and Promotional Materials、Sales Compliance and Investor Suitability、Conflicts of Interest and Fee Disclosure。
- Trading venue/matching system：May trigger ATS/Exchange regulatory framework，need in business model、Order processing、Conduct assessments on market surveillance and record keeping。
- Crypto asset related business：If it involves judging the attributes of securities、secondary trading、hosting、loan、pledge、Income products and token issuance arrangements，Need to conduct regulatory classification and compliance path demonstration。
- Cybersecurity and data protection：and customer information、business continuity、Third party outsourcing、Establishment of systems and evidence chains related to incident response and disclosure。
The scope of SEC compliance support that Hong Kong Xintong can deliver
Based on business process、Product structure、Customer type、Funds and Information Flow，Mapping Advisers Act/Exchange Act and common SEC inspection topics，Develop a gap list and rectification roadmap。
Build a compliance governance and three lines of defense framework：Compliance Manual、Supervision and inspection plan、Compliance meeting and reporting mechanism、Exception approval and upgrade mechanism (escalation)。
carding fee、rebate、soft dollar、Related parties、Order routing、Conflict points such as investment research/trading isolation；Output disclosure text template and approval trace requirements。
promotional materials、Website content、road show skills、KOL/channel content reviewed；Standardize performance calculation caliber、Risk warning、Appropriateness and retained evidence chain。
around written policies、Customer communication、Transactions and Valuations、Approval flow and log retention，Planning record directory、Retention period and access control，Improve inspection response efficiency。
In scenarios involving capital flow and customer identification，Connecting KYC/KYB、Transaction monitoring、Sanctions screening and suspicious activity reporting (if applicable)，And make RACI division of cross-border team responsibilities。
Establish access control、Supplier management、Data classification and encryption、Incident classification and notification process；Form a closed loop of drill records and rectification，Meet inspection and evidence collection needs。
Mock exam、Evidence inventory and data room preparation、Inquiry caliber、Improvement plan and board/management reporting materials，Reduce the risk of inconsistent statements and omissions。
Implementation process (from assessment to operational compliance system)
Interview key positions and collect processes、contract、Disclosure and System Information；Identify SEC trigger points and high-risk links。
Output gap matrix (system/process/system/record/personnel)，by priority、Cost and time to develop implementation plan。
Prepare/optimize policies、SOP、Approval forms and trace requirements；Clarify the division of responsibilities and critical control points (KCP)。
Carry out role-based training for front, middle and back offices；Sample test transactions、marketing、Disclosure and Record Retention Effectiveness。
Establish compliance monitoring indicators、Periodic review and exception management；Prepare regulatory inspection data room and inquiry response mechanism。
List of core deliverables (example)
- Regulatory Applicability Memorandum (Non-Legal Opinion)：business model、Customer/Geographical、Product and capital flow analysis；Key Compliance Risks and Recommended Pathways。
- Gap assessment report and rectification roadmap：risk classification、Rectification priority、Responsible person、Timetable and Acceptance Criteria。
- Compliance Manual and SOP Package：Compliance governance、conflict of interest、marketing review、Complaint handling、Transaction and Valuation Control、Outsourcing management、Information security and BCP, etc.。
- Disclosure and Marketing Material Templates：Risk disclosure、Fee and Conflict Disclosure Points、Performance display caliber、Disclaimer and Approval Trace Requirements。
- Record retention and data room inventory：Record directory、shelf life、Authority Management and Sampling Checklist；Check Inquiry Response Ledger Template。
- Training and assessment materials：On-the-job training courseware、Quiz bank、Training sign-in and retention requirements。
- Mock Exam and rectification closed loop：Sampling test、Discovery、Root cause analysis (RCA)、CAPA rectification plan and review records。
If you need a unified design for "cross-border business compliance and multi-jurisdictional collaboration"，Can be combinedCross-border business complianceplan；Involving high-frequency needs for external publicity and promotion materials，Can be performed simultaneouslyMarketing material review。
Cost and cycle (reference)
SEC compliance support is typically organized by “business complexity + Target status (registered/in camp/inspection response) + delivery depth (system/system/retention/training)" pricing。To facilitate budget communication，One is provided belowBenchmarking Reference Matrix (HK MSO)As an example of cost caliber；The actual SEC project will be based on the requirements statement and workload assessment.。
| category | project | Reference fee (HKD) | illustrate |
|---|---|---|---|
| Gov | Application | 3,310 | Example of government application cost caliber |
| Gov | Fit & Proper | 860/people | Calculated based on the number of key personnel |
| Base | Company Reg | 8,000–15,000 | Example of company registration/basic administrative cost range |
| Base | Office | 20,000–80,000/year | Examples of office and physical operating cost ranges |
| Agency | MSO service | 60,000–150,000 | Example of consulting service cost caliber (fluctuating by scope and depth) |
| Agency | AML Docs | 20,000–80,000 | Institutional documents and process packages (floating according to complexity) |
| Total | Standard | 150,000–400,000 | Example of standard interval caliber |
Cycle reference：Gap assessment usually takes 2–4 weeks；4-8 weeks for systems and procedures to be implemented；Such as including simulation inspection and multi-department training，The overall period can be extended to 8-12 weeks (depending on the completeness of the data and the pace of coordination)。
FAQ (frequently asked questions)
may。Whether it is triggered depends on whether you are marketing/selling to US investors、Whether securities-related services are provided、"Material factors" such as whether solicitation or trading activities are conducted in the United States。It is recommended to sort out regulatory applicability and business flow first.，Then decide on the compliance path and organizational structure。
Common high risks include：Insufficient disclosure of conflicts of interest、Marketing and performance presentations are exaggerated or lack evidence.、Cost accrual and allocation are not transparent、A written system exists but is not implemented、Incomplete or non-retroactive record keeping、Outsourcing and weak cybersecurity controls、Insufficient disclosure of customer suitability and risks, etc.。
Involving U.S. legal opinions、Registration declaration documents、Formal legal representation to the regulatory authority，Typically requires support from a U.S. licensed attorney/consultant。Hong Kong Xintong focuses on "implementation of compliance operations"：gap assessment、Institutional process and trace system、Marketing review and record retention、Check preparedness，And can work with your U.S. lawyer team to advance。
Can。We can establish a closed-loop mechanism of "material classification + approval process + evidence retention"，Cover official website、white paper、Roadshow PPT、Company media content、Channel placement、KOL copywriting and external email templates, etc.，and linked to appropriateness and disclosure requirements。
The system is just a tool。SEC-related inspections place more emphasis on systems、Execution and evidence chain：Is the risk assessment regularly updated?、Is there a ledger for list screening and alarm handling?、Does exception approval leave traces?、Whether training and random inspections are ongoing。We can align system capabilities with institutional processes，Form an auditable compliance loop。
