Offshore Banking Regulation Reform

Hong Kong Offshore Banking Regulation Reform Group 8 Interim Deliverable II• Year 3 Surveying Studio • 30 November 2009

HK as Asia’s Offshore Financial Center • URL: http://hkofc.blogspot.com/!

SUBJECT: OFFSHORE BANKING REGULATION REFORM!

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SURVEYING STUDIO III

PART I: Current Banking Regulations in Hong Kong Banking services is the most essential element of an OFC to provide financing and funding for investment. The banking sector of Hong Kong is basically regulated by the Banking Ordinance. O!shore business investors appreciate the current business environment mainly due to the low tax policy as discussed in the previous deliverable. However, doing banking business in Hong Kong is not as easy as operating other types of trading activities. A series of requirements have to be fulfilled before a new bank can be register in Hong Kong.

1.1 Cap. 155 - Banking Ordinance It is important for a jurisdiction to regulate the banking sector mainly for the confidence of general public. Under the ordinance, there are 3 types of Authorized Institutions (AIs) allowed in Hong Kong, namely the licensed banks, restricted licensed banks (RLBs) and deposit taking companies (DTCs). Their minimum of registration, hence the entry barrier is shown in the below table:

Min. Deposit Min. Deposit Maturity Min. paid-up Capital

Min. shares of AI Min. Assets Domestic Banking

Licensed Banks N/A N/A Local Foreign banks: banks: HKD USD 16 150m billion HKD 3 billion HKD 4 billion Yes

RLBs HKD 0.5m 24-hour HKD 100m

DTCs HKD 0.1m 3 months HKD 25m

N/A N/A No

N/A N/A No

We can see that it is di"cult for foreign banks to be licensed in Hong Kong. The entry barrier is high which requires a very strong capital base. The ordinance aims at protect the banking sector and the depositor by setting entry, product line and ratio controls.

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The entry control can be explained by the table above while the product line control mainly deals with the amount loan allowed to lend. For example, the maximum amount of mortgage that is permitted under the Banking Ordinance is 70%. This is important when considering the potential investments by o!shore companies as they may need financing for purchasing properties and investments. The ratio control focuses on the capital base of the AIs. It is required that any AIs should have a minimum liquidity ratio (Liquefiable assets/ Qualifying Liabilities) of 25% and capital adequacy ratio (Capital base/ Risky Assets) of 8%. • Abolishment of Estate Tax: Nevertheless, the abolishment of estate tax in 2005 induced an

incentive for new foreign investor. The Revenue (Abolition of Estate Duty) Ordinance 2005 is not just simply a kind of tax structure reform but also a reformulation of business policy for future development. The tax reform in 2005 is relatively not that e!ective since the mainland China also has no estate tax. The competitiveness of Hong Kong is not much enhance when compared to Shanghai as the financial centre of PRC. Although it sounds frustrating, the change in attitude shows a sign of aggression for a better future development.

1.2 The Regulatory Authorities In Hong Kong, currently, many di!erent financial institutions appear in the fund market. For example, licensed banks, which escape the banking regulation for strict supervisory by setting up Special Investment Vehicles(SPVs) to make investment in fund market. Like licensed banks, other types of financial institutions which are not originally players in fund market may seek profitable opportunities here. Because in Hong Kong, the market monitoring system is not based on a single root, di!erent types of institutions are regulated by di!erent authorities, the fund investment industry is currently monitored by a number of regulators due to the background of di!erent players. The institutions that involve in the regulation of fund investment are listed below: • Hong Kong Monetary Authority (HKMA) • Securities and Futures Commission (SFC) • Hong Kong Association of Banks (HKAB) • O"ce of Commissioner of Insurance

From the lesson we learnt from the sub-prime mortgage crisis in 2008, or rather, from the lesson we learnt from the fact that HKMA and SFC blamed and shifted the responsibilities to each other for PAGE 2 OF 17!

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the seriously impacted mini-bond issue, we could find out that the financial regulation framework in Hong Kong has its defects as commonly the same situations all over the world, and when there is a severe financial crisis, the current regulation framework will not help to resolve the outstanding problems but to make the situation even worse. It seems that the regulation bodies are quite complete, but actually it shows a problem of over-bureaucracy, however, lack of detailed regulations. Moreover, because nowadays, each area of financial market is no longer as separated as it was before. The interaction and more importantly, interpenetration between each sections(banks, insurance firms, finance companies, investment banks, funds) is more prosperous than before, it is also the reason why the market is so active these years. To regulation framework, the traditional divided one could no longer apply to today`s situation very well, as the response speed to outstanding issue is not adequate to fulfill the current market requirement, also the responsibility between each bureau could not be easily defined as before. In conclusion, the market calls for a converge of di!erent regulatory bodies under a special and whole-functioned regulation framework to deal with the comprehensiveness of current financial market. It is the global trend in financial regulation. As Hong Kong is envisaged to be a future crucial o!shore financial center in Asian region, it is urgent for Hong Kong to take the steps faster than other competitive zones to revise its regulatory framework and make further improvements.

1.3 The Clearing System HKMA established the Real Time Gross Settlement (RTGS) system in December 1996, which provides smooth and e"cient settlement for interbank payments. The Hong Kong Dollar RTGS system has a single-tier settlement structure with all banks maintaining settlement accounts with HKMA. All RTGS payment transactions are settled in real time across the books of HKMA. HKMA introduced the US dollar RTGS system and euro RTGS system in August 2000 and April 2003 respectively. These allow participants to settle US dollar and euro transactions real time in the Asian time zone. By making use of the payment versus payment (PvP) linkages between the three RTGS systems, foreign exchange settlement risk caused by the time gap between the settlement of Hong Kong dollar, US dollars and the euro can be eliminated. Since their implementation, the US Dollar and euro Clearing Systems have operated smoothly. The Renminbi Settlement System, launched in March 2006, was upgraded to Renminbi RTGS system in June 2007 to cater for the expanded renminbi business in Hong Kong. In November 2006, HKMA and Bank Negara Malaysia launched a cross-border PvP linkage such that both legs of the foreign exchange

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transactions between the US dollars and Malaysian Ringgit can be settled simultaneously in the Asian time zone. Hong Kong follows the British system where checks (‘cheques’) may be used by the bearer unless the words ‘or bearer’ are crossed out and may be cashed, unless two parallel lines are drawn on the face of the check - which means they can only be deposited into the named account. Hong Kong dollar, US dollar or Renminbi checks issued by local banks generally clear overnight. Foreign checks issued by overseas financial institutions clearing times depend on your relationship with your banker: Sometimes banks will buy a foreign check immediately, while at other times overseas checks take three weeks to clear. Many banks now charge a small fee if you deposit a foreign check into a foreign currency account.1

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http://www.amcham.org.hk/hongkong/eohk/20_The_Banking_Sys.pdf PAGE 4 OF 17!

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PART II: Current Investment Regulations in Hong Kong Hong Kong has a well developed fund management sector with a sophisticated regulatory framework, which is internationally regarded as being of a high standard. According to KPMG` report2, as at 31 December 2007, 2,123 unit trusts or mutual funds had been authorized by the SFC, with a net asset value of USD 1,077 billion under management.

2.1 Types of funds in Hong Kong The collective investment funds which are originated in Hong Kong should take the organization of either mutual funds or unit trusts. They could choose to be authorized or not authorized by the Hong Kong Securities and Futures Commission(SFC). However, if they would like to be marketed to the public and to be listed in the Stock Exchange, they must first be authorized and subject to a strict regulation control. Authorized funds could be further classified into the following categories 3: • Equities funds • Bonds funds • Unit portfolio management funds(invest in other funds & trusts) • Money market/cash management funds • Warrant funds • Leveraged funds • Futures and option funds • Guaranteed funds • Index funds • Hedge funds

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KPMG(2009), “International funds and fund management survey”, p4, website: http://www.kpmg.com/Global/ IssuesAndInsights/ArticlesAndPublications/Pages/Funds-and-fund-management.aspx 3

Hong Kong Securities and Futures Commission website: http://www.sfc.hk/sfc/html/EN/ PAGE 5 OF 17!

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• Index tracking exchange traded funds • Real estate investment trusts

Each type of funds will be subject to di!erent regulation controls. Some will be controlled more strictly by SFC, some will be less controlled according to their characteristics.

2.2 Regulations and laws Regulation body

The authorizing body for unit trusts and mutual funds is SFC under Section 104 of the Securities and Futures Ordinance. To administer the Unit Trust Code and authorize a trust or fund through application, a Committee on Unit Trusts is established under SFC. Any matter relevant to a trust or fund authorization should be through this Committee. The Unit Trust Code

Code on Unit Trusts and Mutual Funds(a.k.a. Unit Trust Code) applies to authorized funds by SFC. The Code establishes guidelines for the authorization of collective investment schemes in the nature of mutual fund corporations or unit trusts, and codifies practices established in relation to the former Code on Unit Trusts and Mutual Funds published pursuant to the Securities and Futures Ordinance. However, the Code does not have the force of law4. Advantages of authorization

In compliance with the Unit Trust Code, a trust or fund could apply for the SFC`s authorization. According to KPMG`s report, The major advantages resulting from authorization are: • advertising and marketing to the general public in Hong Kong is permitted; • exemption is given from Hong Kong profits tax; and • listing on the Hong Kong Stock Exchange is greatly facilitated.

Money Laundering

The Guideline on Money Laundering issued by the Hong Kong Monetary Authority expects to minimize the chances to launder money earned from criminal activities and to finance terrorist activities. In particular institutions should verify the true identity of all customers requesting the

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Abstract of Code on Units Trusts and Mutual Funds, first edition pursuant to the Securities and Futures Ordinance (Cap. 571), Securities and Futures Commission(2003) PAGE 6 OF 17!

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institution’s services. In particular, the following areas should be verified according to the Guideline:5 • Client identification • Record keeping • Period of retention of records • Recognition and reporting of suspicious transactions • Procedures for disclosure • Education and training

Borrowing of funds or trusts

According to the Unit Trust Code, the maximum borrowing of a fund must not exceed 25 percent of its net asset value, except that for a capital markets scheme, borrowing must not exceed 10 percent of its net asset value.6 Investment Restrictions 7

According to KPMG`s report, the principal restriction on the investment powers of authorized funds in Hong Kong, other than warrant funds, leveraged funds, futures and options funds, real estate investment trusts are: • prohibition on investment in real estate except for shares in real estate companies and interests

in real estate investment trusts (REITs); • holding of securities issued by any single issuer may not exceed 10 percent of fund’s net asset

value, except that this rule is relaxed in the case of government and other public securities; • the fund may not hold more than 10 percent of any class of security issued by any single issuer,

except that this rule is relaxed in the case of government and other public securities; • the fund may not have more than 15 percent of net asset value invested in unquoted or unlisted

securities;

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Guideline on Money Laundering, Hong Kong Monetary Authority (1997)

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Code on Units Trusts and Mutual Funds, Securities and Futures Commission(2003)

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KPMG(2009), “International funds and fund management survey”, p5, website: http://www.kpmg.com/Global/ IssuesAndInsights/ArticlesAndPublications/Pages/Funds-and-fund-management.aspx PAGE 7 OF 17!

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• options, warrants, and financial futures can be bought for hedging purposes, but the following

restrictions apply to other activities involving these financial instruments: • no more than 15 percent (options and warrants) or 20 percent (financial futures) of net asset value

can be invested in such instruments for purposes other than hedging; • writing of call options on portfolio investments may not exceed 25 percent of a fund’s total net

asset value in terms of exercise price; • holdings of units or shares in other collective investment funds cannot exceed in aggregate 10

percent of net asset value but this is relaxed in the case of a feeder fund or a unit portfolio management fund; • there are also restrictions on short selling, investment in nil or partly-paid shares and in securities

in which directors or o"cers of the management company have an interest; and separate restrictions apply to specialized funds, such as unit portfolio management funds, money market/cash management funds, warrant funds, leveraged funds, futures and options funds, guaranteed funds, index funds, hedge funds, index tracking exchange traded funds, and real estate investment trusts. Managers, trustees, and custodians

For authorization purpose, every mutual fund or unit trust is required to appoint a management company (except for self-managed funds). According to Code on Unit Trusts and Mutual Funds 5.2, a management company must:8 1.

be engaged primarily in the business of fund management;

2. have su"cient financial resources at its disposal to enable it to conduct its business e!ectively

and meet its liabilities; in particular, it must have a minimum issued and paid-up capital and capital reserves of HK$1 million or its equivalent in foreign currency; 3. not lend to a material extent; and 4. maintain at all times a positive net asset position.

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Chapter 5.2, Code on Units Trusts and Mutual Funds, Securities and Futures Commission(2003) PAGE 8 OF 17!

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Also according to Code on Unit Trusts and Mutual Funds 4.1&4.2&4.3, every collective investment scheme for which authorization is requested must appoint a trustee/custodian acceptable to the Commission. And a trustee/custodian must be:9 (a) a Hong Kong licensed bank; or (b) a trust company which is a subsidiary of such a bank; or (c) a registered trust company; or (d) a banking institution or trust company incorporated outside Hong Kong which is acceptable to

the Commission.

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Chapter 4.1&4.2&4.3, Code on Units Trusts and Mutual Funds, Securities and Futures Commission(2003) PAGE 9 OF 17!

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PART III: Reform Proposal 2.1 Separation of ACU and DBU It was recognized that given appropriate support and incentives, a market similar to the Eurodollar could be developed in Hong Kong. As a site for this o!shore market, Hong Kong o!ers several advantages including a sound financial infrastructure, an excellent communications network, a comprehensive legal system, a stable government and a geographical location with a time zone advantage. To allow for better domestic monetary control and encourage o!shore finance activities, Asian Currency Unit (ACU) and Domestic Banking Unit (DBU) should be set up to separate the booking for Hong Kong Dollar and other currencies such as US Dollar and RMB . Any financial institution seeking approval to operate in US dollar market or RMB market is required to set up a separate book-keeping unit for such transactions. ACU is permitted to accept deposits from, and lend to other banks and non-bank customers in all currencies other than the Hong Kong dollar. ACU should be subject to less regulatory rules and requirement so that the o!shore market could be developed by o!ering more incentive for investors to borrow and lend foreign currencies. Rationale for allowing banks to operate ACUs

ACUs are designed to facilitate the funds flows denominated in non-HKD currencies. With the development of China’s economy, there will be plenty of investment opportunities in China, which provides chances for Hong Kong to be the intermediary between foreign investors and Chinese fund-seekers. To attract mutual funds as well as special investments such as hedge funds to set up in Hong Kong, incentives to transact in foreign currencies should be provided. The ACU is subject to fewer regulatory rules and requirements than the DBU. Banks are therefore able to accept non-HKD deposits and lend out non-HKD funds more freely through the ACU, paving the way for the creation of the ADM in Hong Kong (the counterpart of the eurodollar market in London). In addition, unlike in the DBU, statutory reserves need not be maintained for deposit liabilities in the ACU.

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Funds raised in the ACU from overseas bank and non-bank depositors will be largely re-channelled out of Hong Kong through placements with banks and loans to non-bank borrowers outside Hong Kong. Rationale for allowing banks to operate DBUs

After the 1998 financial crisis in Hong Kong, the importance of maintaining a robust currency to protect Hong Kong’s economy has been enhanced. In the process of developing into an o!shore finance center, Hong Kong should be cautious of internationalizing its own currency as Hong Kong’s own economic fundamentals are not su"cient to resist a speculative attack. Restriction on DBUs can limit the extension of bank credit in HKD to non-residents except for the purpose of funding economic activities. In addition, some restrictions should be placed on interbank HKD derivatives, such as FX, currency and interest rate swaps and options, which could facilitate the leveraging or hedging of HKD position. These restrictions can make it harder and more costly for potential speculators to short the HKD. However there may be drawbacks: the safeguards put in place under the policy might hinder the development of our capital markets, in particular the bond markets in Hong Kong. In addition, despite the HKD being freely convertible, some potential foreign investors might be deterred from investing in Hong Kong as they did not fully understand the policy.

2.2 Converge of different regulatory bodies We advice Hong Kong government to establish a new institution called “Financial Services Authority(FSA)” to be responsible for the overall supervisory work for all legal financial institutions and markets. Di!erent currently-existed regulatory bodies, for example, HKMA, should be under its management to promote better cooperation between each supervisory body towards comprehensive issues. The FSA should be an independent organization responsible for regulating financial services in Hong Kong. All around the world, there are many examples could be learned to promote this reform. Although there are many countries adopting a regulatory mode just as what is in US, which is a separated supervisory power, such as Hong Kong, China, Canada and Euro-Countries, there are still countries which only have a overall supervisory power to regulate the financial market, such as the UK, Japan and Singapore, to be frank, these countries are not as seriously influenced as the countries using separated regulatory framework by the financial crisis.

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Take Japan for example. The organization chart in the appendix shows how Financial Services Agency in Japan works 10. We could find that all the partial regulatory bodies are under the single control of FSA. There are no more independent bodies of Monetary Authorities, SFC and Insurance Commissions. The conflicts aroused from supervisory process between each division could be coordinated within the FSA. As a result, the whole responsibility for regulating the financial institutions are taken by the FSA, thus it is very clear. A more comparable example is the regulatory framework in Singapore as • Singapore is the biggest Asian o!shore money center, as Hong Kong is moving into an o!shore

fund center, there is much experience that could be learned from a existing successful one. • Both Hong Kong and Singapore are important financial centers in Asian region, especially in

South Asia zone, and they are competitive from history experience. Singapore is a well-developed o!shore financial center, the transaction volume is huge in Asia, according to Monetary Authority of Singapore(MAS), • The Size of Singapore corporate debt market is about S$ 168 billion in 200811 • The Asset Under Management(AUM) as at the end of 2008 stood at S$864 billion12

In Singapore, there is only one financial supervisory body who take in charge of overall regulatory work of Singapore financial market, Monetary Authority of Singapore(MAS). Generally, MAS has the following functions:13 1. To act as the central bank of Singapore, including the conduct of monetary policy, the issuance of currency, the oversight of payment systems and serving as banker to and financial agent of the Government 2. To conduct integrated supervision of financial services and financial stability surveillance 3. To manage the o"cial foreign reserves of Singapore 4. To develop Singapore as an international financial centre

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The Financial Services Agency Japan website, http://www.fsa.go.jp/en/index.html

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The Singapore Corporate Debt Market Review 2008, Monetary Authority of Singapore, http://www.mas.gov.sg/ resource/eco_research/surveys/Debt08.pdf 12

2008 Singapore Asset Management Industry Survey, Monetary Authority of Singapore, http://www.mas.gov.sg/ resource/eco_research/surveys/AssetMgmt08.pdf 13

Monetary Authority of Singapore website, http://www.mas.gov.sg/about_us/Departments_in_MAS.html PAGE 12 OF 17!

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One special department within MAS called “Prudential Policy Department”, it takes overall strategies in the supervisory of each section of the financial market. As the illustration of this department shown on the website of MAS:14 “The Prudential Policy Department (PPD) is responsible for formulating capital and prudential policies for banks, insurance companies and securities firms to promote a sound yet dynamic financial sector.# It works to achieve a more harmonized regulatory framework that will minimize gaps and arbitrage, and facilitate a more integrated risk-based supervisory approach.” It is in our consideration to establish a similar department in Hong Kong to carry out the whole strategies in supervisory work. 2.3 Internationalization of policies and standards We suggest the regulatory body in Hong Kong adopt more international standards to make the regulatory framework more global and well recognized. Although it is always the case that local government should enact the regulation according to local situations, sometimes this kind of regulation will cause much trouble to be recognized by the international investors and therefore discourage them to invest in Hong Kong. For example, to deal with di!erent tax regulation frameworks for entering a potential emerging market will introduce a large transaction cost (research), which will decline the interest for foreign investors if it is too complicated to be coste!ective. However, international standards are more recognized by institutional investors around the world. Also, it is commonly accepted by foreign investors. In terms of reducing transaction cost, it is better for the regulatory body to introduce more internationally-accepted standards into Hong Kong.

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Monetary Authority of Singapore website, http://www.mas.gov.sg/about_us/Departments_in_MAS.html PAGE 13 OF 17!

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Appendix 1. Lists of Laws and regulations governing authorized funds in Hong Kong:15 • Securities and Futures Ordinance • Securities and Futures (Client Money) Rules • Securities and Futures (Client Securities) Rules • Securities and Futures (Financial Resources) Rules • Securities and Futures (Accounts and Audit) Rules • Securities and Futures (Keeping of Records) Rules • Code on Unit Trusts and Mutual Funds (the Unit Trust Code) • Code on Real Estate Investment Trusts • Code on Conduct for Persons Licensed by or Registered with the Securities and Futures

Commission (the General Code)

• Rules Governing the Listing of Securities (Listing Rules) (if listed) • The Drug Tra"cking (Recovery of Proceeds) Ordinance and the Organized and Serious Crime

Ordinance (relevant to the operations of funds as funds might be used to launder money arising from criminal activities as specified in the ordinances)

• Code on Pooled Retirement Funds • Fund Manager Code of Conduct • Management Supervision and Internal Control Guidelines for persons licensed by or registered

with the SFC

• Guidance Note on Internet Regulation • Guidance Note on the Application of the Electronic Transactions Ordinance to Contract

Notes

• Guidance Notes for Persons Advertising or O!ering Collective Investment Schemes on the

Internet

• Guidelines for Registered Persons Using the Internet to Collect Applications for Securities in

an Initial Public O!ering

• Mandatory Provident Funds Schemes Ordinance • Code on MPF Investment Funds !"#$%&&'()*+,#-.#/0123455678#9:;<+(;'=>;'?#@%;,A#';,#@%;,#&';'B+&+;<#A%(C+.D8#E+-A)<+F#GHIFJJEEEKLI&BKM>&J2?>-'?J

:AA%+AN;,:;A)BG;AJ0'B+AJO%;,AP';,P@%;,P&';'B+&+;
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• Code on Disclosure for MPF Investment Funds • SFC Code on Mandatory Provident Fund (MPF) products • Guidelines for Review of Internal Controls and Systems of trustees/custodians • Fit and Proper Guidelines • Guidelines on Competence • Guidelines on marketing materials for listed structured products • Registration Guidelines for intermediaries advising on securities incidental to the marketing of

MPF schemes only.

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2. Organization chart of Financial Services Agency (Japan)

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Reference • American Chamber of Commerce in Hong Kong , “The Banking System”, website: http://

www.amcham.org.hk/hongkong/eohk/20_The_Banking_Sys.pdf

• KPMG(2009), “International funds and fund management survey”,website: http://

www.kpmg.com/Global/IssuesAndInsights/ArticlesAndPublications/Pages/Funds-and-fundmanagement.aspx

• Hong Kong Securities and Futures Commission website: http://www.sfc.hk/sfc/html/EN/

• Securities and Futures Commission(2003), Code on Units Trusts and Mutual Funds, first

edition pursuant to the Securities and Futures Ordinance (Cap.571), Electronic version: http:// www.google.cn/search?hl=zh-CN&client=a!-os-maxthon&hs=ZxG&q=Code+on+Units +Trusts+and+Mutual+funds+HK&aq=f&oq

• Hong Kong Monetary Authority (1997), Guideline on Money Laundering, Electronic version:

http://www.info.gov.hk/hkma/eng/public/qb200211/supplement.pdf

• The Financial Services Agency Japan website, http://www.fsa.go.jp/en/index.html

• The Singapore Corporate Debt Market Review 2008, Monetary Authority of Singapore,

http://www.mas.gov.sg/resource/eco_research/surveys/Debt08.pdf

• 2008 Singapore Asset Management Industry Survey, Monetary Authority of Singapore, http://

www.mas.gov.sg/resource/eco_research/surveys/AssetMgmt08.pdf

• Monetary Authority of Singapore website, http://www.mas.gov.sg/

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