Updated – MFA Hong Kong Client Electronic Trading Services Representation Template

In 2013, MFA developed a Hong Kong Client Electronic Trading Services Representation Template in an effort to assist members with streamlining representations to dealers with respect to electronic trading services.  This month, July 2019, MFA updated its template to take into consideration the Hong Kong Securities and Futures Commission’s (SFC) Fund Manager Code of Conduct.

On March 22, 2013, the SFC issued final electronic trading regulations, which became effective January 1, 2014.  Among other requirements, the SFC amended its Code of Conduct for Persons Licensed by or Registered with the SFC (Code of Conduct) to require an intermediary to perform some basic due diligence on the end user with respect to use of direct market access (DMA) services.  MFA developed a Client Electronic Trading Services Representation Template based on Code of Conduct, Schedule 7, Section 2.2 regarding minimum client requirements for DMA services.

While the Code of Conduct places the obligation to monitor compliance with the SFC’s electronic trading regulations on a licensed/registered intermediary, MFA believes the Client Electronic Trading Services Representation Template may be helpful to members that are asked to make electronic trading services representations by their intermediary.

For a copy of the HK SFC Consultation Conclusion on the Regulation of Electronic Trading, please see:

MFA Hong Kong Client Electronic Trading Services Representation Template