The SFC’s revised Fund Manager Code of Conduct (FMCC), which comes into effect on 17 November 2018, makes reference to a number of policies, guidelines and procedures which a licensed fund manager is expected to maintain. We have prepared a memo for our clients which outlines the main policy requirements and lists an internal document which could be used to record a manager’s policies and compliance procedures in these areas. The SFC may wish to examine these documents on a routine inspection. If you are a Deacons’ client and wish to receive a copy of the memo, please don’t hesitate to inform your usual contact at Deacons.
The text of the revised FMCC is available in this Gazette Notice: https://www.sfc.hk/web/EN/pdf/Gazette/G.N.%208418%20of%202017.pdf