Update on Hong Kong Investor Identification Regime and OTC Reporting Regime
Significant Wins
asifma S
Significant Wins
Growing Asia's Markets
FAQ B.1 - The term "Relevant Client" generally refers to a person which has placed or proposed to place a securities
order through a securities trading account with an relevant regulated intermediary ("RRI")
"Where an order is routed through an intermediating chains of brokers, the "relevant client" is the first person in the
chain who is not an RRI. Generally speaking, the relevant client in this case are the overseas affiliates of the RRIS
instead of the clients of the overseas affiliates. Hence, BCAN should be assigned to the overseas affiliates by the RRI
and should be tagged to the orders placed by the overseas affiliates.
The SFC has stressed during the meeting on 20 December 2021 that this regime is "account based" (i.e. it only applies
to accounts booked in Hong Kong)
Example:
HK Client with accounts booked to Singapore places orders with HK RM → HK RM asks Singapore trader to execute the
trade Singapore trader asks HK EP to execute the trade
HK EP executes the trades and assign BCAN to the Singapore entity - and not the underlying clients.
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