Investor Presentaiton
Implications for US Managers Marketing Private Funds
to Investors in Hong Kong & Mainland China
• People on the Ground
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While only a single person is required to be resident in Hong Kong in order to maintain
an office, there still remain many middle and back office support functions, but these
may be outsourced to the home office, so long as the regulatory requirements are met.
Of note, the person/people on the ground would typically be considered to be so-called
"responsible officers" (and subject to separate "Responsible Officer" license approval by
the SFC) for all filings and representations made by the subsidiary in Hong Kong.
Accordingly, those Responsible Officers should be briefed to understand what their full
responsibilities are in this dual-hatted role. Given the scope of work involved, it may be
preferable to have one front-office and one operations/legal staff resident in Hong Kong
to ensure that all requirements are being met timely.
Morgan Lewis
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