Marketing Material Guidelines and Compliance FAQ
Question
Answer
34.
34A
Performance Information of an Unauthorized Scheme
For newly authorized schemes, is it
permissible to present the performance
information of such schemes prior to their
authorization?
An SFC-authorized scheme adopts the same
investment strategy as another unauthorized
scheme ("Other Scheme") which is managed by
the same fund management group. If the
management company wishes to provide
additional information to investors relating to the
investment experience of the fund management
group (to which this management company
belongs) in managing a particular strategy, can
they present the past performance information
of the Other Scheme in the advertisements of
the SFC-authorized scheme?
Yes, performance information of newly authorized schemes may be presented so long as the
schemes have attained a track record of not less than 6 months.
Advertisements may not refer to unauthorized schemes, except in compliance with the
Advertising Guidelines. Reference to past performance of an unauthorized scheme to indicate
the management company's past track record is allowed if the SFC-authorized scheme is
newly launched with a past track record of less than 6 months and subject to the conditions
contained in paragraph 22 of the Advertising Guidelines.
For an SFC-authorized scheme which has attained a track record of 6 months, if the
management company wishes to provide additional information regarding the investment
experience of the fund management group (to which the management company belongs) in
managing a particular investment strategy, the management company is only allowed to
present the past performance information of an unauthorized scheme (i.e. the Other Scheme)
prior to the launch of the SFC-authorized scheme in the advertisements of the SFC-
authorized scheme ("Advertisements"), provided that the following requirements can be
fulfilled:
a. the Other Scheme must be managed by the same fund management group and must
have the same investment strategy, restrictions and risk profile ("Same Features and
Risks") as the SFC-authorized scheme presented in the Advertisements;
b. only the past performance information of the Other Scheme which should cover a
minimum of 5 years (or the period since launch if shorter) immediately preceding the
launch of the SFC-authorized scheme can be presented;
c. presentation of performance information of the Other Scheme pertaining to the period
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