A new Short Position Reporting Regime came into effect in Hong Kong on June 18, 2012, as previously reported in our advisory, New Short Position Reporting Regime in Hong Kong. The first day for which a report must be filed with the Securities and Futures Commission (SFC) was Friday, June 22, 2012, and the deadline for filing the first report was midnight (Hong Kong time) on Tuesday, June 26, 2012.
One of the requirements of the new regime that directly concerns partnerships is the obligation to file with the SFC the particulars of all of the partners in a partnership in a prescribed format. However, the SFC has issued informal advice relaxing this requirement and requiring only that the particulars of the partnership and the general partner be filed.
This is a positive development for partnerships, as the SFC has recognized the difficulties that partnerships face with reporting information about their limited partners. However, the SFC reserved the right to call for the full information from partnerships in the future.