Update on Hong Kong Investor Identification Regime and OTC Reporting Regime

Updates/"Mapping" asifma S Updates/"Mapping" Growing Asia's Markets Following the publication of the consultation conclusion, ASIFMA and S&S submitted a letter to the SFC, requesting clarification in the following areas: *Highlighted cell means the SFC has only partially responded Clarification Bonds - whether bonds which are listed on the SEHK but traded OTC will be in-scope of the HKIDR and OTCR Trade Give Up - we request for flexibility for relevant regulated intermediaries ("RRI") to assign BCAN in a trade give up Scenario. We have requested for clarification in our responses to the consultation paper Response by the SFC Question A.1 Even if the bonds are listed, if you trade bonds on an OTC basis, it is not in-scope of the HKIDR Question B.2 "The HKIDR applies at the trading level, and not at the settlement level. There is no requirement to assign BCAN to the beneficial owner of an executed trade if they are not the "Relevant Clients" of the RRI. The BCAN tagged to the order should not be changed throughout the trade execution even though the executed trade is subsequently given up to a prime broker. L_LIVE_APAC1:8040846v1 10

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