ALFI responds to the SFC consultation on the revision of the Hong-Kong Code

The consultation covered, among others, proposed amendments regarding financial derivative instruments, product classification, liquidity risk management, Money Market Funds, key personnel requirements, and notification requirements.

In its targeted response, ALFI overall welcomes many of the SFC proposals, such as the optional use of the Value-at-Risk (VaR) approach and recognition of overseas management company governance for key personnel compliance. ALFI also asks for further clarifications, e.g. to streamline the classification of (non-)complex products with the EU MiFID regime to further facilitate cross-border fund registration. However, in line with its long-standing position, as articulated in the response to the 2021 FSB consultation referenced by the SFC, ALFI disagrees with the proposed higher liquidity levels for Money Market Funds.

View the ALFI response.