Investor Presentaiton
SFC
證監會
7. Practical tips and common misconceptions
Investment managers
■ Q: Can the investment manager of an OFC be an OFC director?
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The OFC must have at least two individual directors, with at least
one independent director, who must not be a director or employee of
the custodian
Directors/responsible officers of the investment manager can be
OFC directors
Q: Can the investment manager of an OFC also act as the
custodian?
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The custodian must be a separate legal entity from the investment
manager of an OFC for investor protection purposes
If the custodian and the investment manager are bodies corporate
having the same ultimate holding company, the custodian must be
functionally independent of the investment manager
Internal controls must be in place to ensure persons fulfilling the
custodial function are functionally independent from those fulfilling
the investment management functions
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