1. Type 9 license (providing asset management) statutory business functions
Discretionary Portfolio Management
Manage securities or futures contract investment portfolios for clients on a discretionary basis。The statutory scope centers on managing a portfolio of securities or futures contracts.，Specific products and activities must still be judged based on license conditions and other applicable systems.。
Discretionary fund management
Manage funds on a discretionary basis。Equivalent to mainland public offering、Private equity fund license，But there are fewer restrictions on investment targets，Via Shanghai-Hong Kong Stock Connect、Shenzhen-Hong Kong Stock Connect reverse investment in A shares。
Real Estate Investment Plan Management
according toSecurities and Futures Ordinance，Class 9 licensestatutory business includes more than just securities or futures contract management，Also expressly covers the management of real estate investment plans。
virtual assets (VA) investment management
When the investment portfolio intends to invest in virtual assets reaches or exceeds 10% of total assets，Or when managing a pure virtual asset portfolio，The SFC will impose terms and conditions applicable to virtual asset fund managers on the Type 9 license；This is not another statutory "upgrade license"。
2. Common market name and formal license conditions of Type 9 license
The Category 9 license with the condition "not to hold client assets" is sometimes called "Little 9" in the market.，But this is not a statutory license category。Client assets should be properly safeguarded by qualified arrangements，Not to be confused with the licensed corporation’s own assets；Customers and product scope must still be judged based on actual license conditions。
Category 9 licensed corporations that are not subject to the “not to hold client assets” condition are subject to higher financial resource requirements，However, this does not mean that client assets can be transferred to the corporation’s own account for unified management.。Holding or controlling client assets is subject to client assets、storage、Applicable rules such as records and internal controls。
The Type 9 license itself is not equivalent to the qualification of a public fund，Nor is it automatically authorized to raise funds from retail investors or manage public offerings.。Funds and products for non-professional investors or publicly offered，Must be separately approved、Applicable systems at sales and product level。
Manage Virtual Asset Portfolio：When virtual asset investment reaches or exceeds 10% of total assets，Or when managing a pure virtual asset portfolio，SFC will impose VAFM terms and conditions on existing Class 9 licenses，and evaluate corresponding technologies、storage、Risk management and internal control arrangements。
3. Core [Statutory Conditions] for Applying for No. 9 License
1. corporate entity：Must be a company incorporated in Hong Kong or an overseas company registered with the Hong Kong Companies Registry。
2. Competencies and internal controls：The corporation has a suitable business structure、Good internal control system and qualified personnel team，Sufficient to properly manage business risks。
3. Responsible person (RO) Configuration：Appoint at least 2 ROs for direct supervision of each regulated activity，At least one of them is an executive director，And must ensure that at least 1 RO can contact and supervise the business at any time。RO competencies according to academic qualifications、Industry qualifications、Relevant experience、Management experience、Local Regulatory Examination and Applicable Exemption Portfolio Assessment，5 years of experience is not always required。
4. Core Function Manager (MIC)：The information of the core functional manager of the corporation must be clearly provided，Establish a sound executive accountability structure。
5. fit and proper person (Fit & Proper)：Major shareholder of the corporation、Directors and senior management must be financially sound (no bankruptcy/debt issues)，No criminal or regulatory record，And have relevant academic qualifications and experience。
4. [Capital and fees] threshold for applying for No. 9 license
| Institutional business conditions restrictions | Minimum paid-up share capital (Paid-up Capital) | minimum liquidity (Liquid Capital) |
|---|---|---|
| There is a licensing condition of "not to hold client assets" | not applicable (No hard requirements) | $100,000 Hong Kong dollar |
| Other situations | $5,000,000 Hong Kong dollar | $3,000,000 Hong Kong dollar |
| SFC official application fee | The application fee and individual application fee must be checked against the SFC WINGS and the current fee schedule at the time of submission；Old amounts that have not been reviewed by the current fee schedule will not be used on this page.。 | |
Note：Liquid capital refers to assets that can be quickly converted into cash or are already in cash form。If you apply for both big and small brands together (such as 1、4、9Number)，The capital requirement is whichever is highest (usually sharing 3 million liquid capital requirement)。
5. Dual-track statutory [process] for obtaining No. 9 license
【Path A】Apply directly to SFC
Determine the subject first、Equity、Business scope、capital、office、RO and internal control system，Prepare and submit application。The normal processing reference announced by SFC is about 15 weeks for corporations、RO about 10 weeks，But only applies to complete applications，The actual time will depend on the replacement parts、capital、personnel、visa、Other regulatory responses and caseloads vary。
【Path B】Acquisition of equity interests in licensed corporations
Any arrangement to directly or indirectly become a substantial shareholder of a licensed corporation，In principle, you must apply for SFC approval in advance in accordance with Section 132 of the Securities and Futures Ordinance.；This requirement is not automatically waived if the controlling shareholder is located in the BVI or other jurisdictions.。Actual time depends on transaction structure、due diligence、Source of funds、Fit and proper review and regulatory supplements。
6. Core information that customers need to prepare and provide to Hong Kong Huitong
1. Basic background information of Hong Kong company (company registration certificate、Business registration certificate, etc.) and equity structure table。
2. Bank account financial certificate to maintain minimum paid-up share capital and liquid capital。
3. major shareholder、director、Proof of “fit and proper” qualifications for senior managers (e.g. no criminal record)、Statement of financial soundness, etc.)。
4. Responsible Officer (RO) Qualifications、Experience and professional certificates (need to prove that they have discretionary asset management experience)。
5. Company organizational chart and core functional managers(MIC)register。
6. Detailed business plan (Hong Kong Huitong can assist in writing and improving it)。
7. Hong Kong Huitong's one-stop shop [Agency services and fees included]
Assistance in applying for services directly (All-inclusive application fee)
Can assist with office planning based on project scope、Responsible person candidate information evaluation、Application form、business plan、AML and internal monitoring document preparation，and coordinate regulatory inquiries、Certification and legal advice。Personnel recruitment、Salary、The length of the document and third-party opinions should be determined based on real needs and independent professional judgment.，No fixed discount or page count commitments。
Assistance in mergers and acquisitions of licensed subject services
Screen clean targets through unique channels；conductHong Kong electronic legislation：Anti-money laundering、Debt pre-review；Interview and draft MOU；Arrange for lawyers and accountants to perform in-depth due diligence(DD)and audit；Prepare SPA Agreement；Complete SFC filing approval and bank tax transfer。
8. Ongoing Responsibilities of Licensed Corporations and [Annual Maintenance] Checklist
1. Licenses and Fees：After obtaining the license, the annual fee must be paid within one month after the same day of the same month every year.(HK$4,740)and submit annual return。
2. financial reporting (FRR)：The Big 9 are required to submit a financial resources declaration form to the SFC every month；Small 9 cards (which do not hold client assets) only need to be submitted once every six months。
3. Audit and Tax：Submit audited accounts within four months after the end of each financial year。Annual corporate income tax and employer tax returns(Form 56A/56B)declare。
4. Change notification：Financial year end date (within 1 month of licensing)、Change of application information、All changes in directors (within 7 days) must be notified to SFC in a timely manner。
5. basic compliance：Maintain business registration、company secretary、Designated representative services，RO and staff are required to participate in ongoing professional training(CPT)。
9. Risks and remedies for license application rejection
Failure to meet "fit and proper" qualifications：If the major shareholder or RO has bad records、Poor financial situation or experience mismatch，SFC will reject the application。
Submissions and Review Mechanism：SFC before rejecting the application，Corporations/individuals will be given the opportunity to make submissions。If it is still rejected in the end，A review can be lodged with the Securities and Futures Appeals Tribunal within 21 days。
Serious consequences of operating without a license：Carrying out regulated activities in Hong Kong without a license，or actively promote such services，It is a serious criminal offence.。
10. Hong Kong No. 9 Financial License Core Legal Questions and Answers (FAQ)
Type 9 license is the “Provision of Asset Management” license，Allow licensed institutions to manage securities or futures contract portfolios for clients on a discretionary basis，and managing real estate investment plans.。Whether private placement is involved、public offering or specific product，It must also be judged based on the license conditions and applicable product systems.。
What the market calls "small 9" usually refers to the Type 9 license with the condition "not to hold client assets"。There is no minimum paid-up capital requirement under this condition，Minimum working capital is HK$100,000；Is it suitable for specific funds?，Still subject to investment authorization、custody arrangements、Customer and product system assessment。
When there is a condition of "not to hold client assets"，No minimum paid-up share capital requirement，Minimum working capital is HK$100,000；In other cases, the minimum paid-up share capital is HK$5 million、Minimum working capital is HKD 3 million。Whether it can serve clients other than professional investors，Depends on actual license conditions and applicable product systems，cannot be directly inferred from the capital grade。
Can，However, it must be judged based on investment proportion and business arrangements.。When the investment portfolio intends to invest in virtual assets reaches or exceeds 10% of total assets，Or when managing a pure virtual asset portfolio，SFC to impose VAFM terms and conditions on Class 9 licenses，and review related risk management and internal controls。
At least two ROs must be appointed to oversee Category 9 businesses，At least one of them shall be an executive director，And ensure that at least one RO is available to contact and oversee the business at all times。Competencies by academic qualifications、Industry qualifications、Relevant experience、Management experience、Local Regulatory Examination and Applicable Exemption Portfolio Assessment，It does not always require 5 years of experience or the same exam path.。
SFC will strictly scrutinize the company’s major shareholders、Financial soundness of directors and officers (no bankruptcy/inability to pay debts)、Credibility and character (no domestic or foreign regulatory sanctions or criminal record)，and whether they have qualified academic qualifications or industry professional qualifications。
The normal processing reference announced by the SFC is approximately 15 weeks for applications from licensed corporations.、RO application takes about 10 weeks，But this is not a guaranteed period，Applies to complete applications only；The actual time will depend on the replacement parts、capital、personnel、visa、Other regulatory responses and caseloads vary。
Any arrangement to directly or indirectly become a substantial shareholder of a licensed corporation，In principle, you must apply for SFC approval in advance in accordance with Section 132 of the Securities and Futures Ordinance.；BVI or other offshore holding structures will not automatically become post-filing。Actual time depends on transaction structure、due diligence、Source of funds、Fit and proper review and regulatory supplements。
The statutory scope of Type 9 regulated activity is mainly the management of securities or futures contract investment portfolios for others，and managing real estate investment plans.。specific market、product、Cross-border arrangements and trading channels must still be judged according to license conditions and other applicable systems。
SFC strengthens executive accountability，Require licensed corporations to clearly designate those responsible for compliance、Risk control、finance、Manager (MIC) of core business modules such as IT and anti-money laundering，and file its information and organizational chart with SFC.。
According to the Financial Resources Rules，Big 9 players (who hold client assets) must submit monthly financial resource declarations to the SFC。If it is a small 9 card (does not hold client assets)，will be relaxed to be submitted once every six months.。
SFC before making a decision to reject，Applicants will be given an opportunity to make submissions and explain。If it is still rejected in the end，Applicants have the right to，Formal submission of review to Hong Kong’s Securities and Futures Appeals Tribunal。
Hong Kong Huitong can assist with office plans within the agreed scope、Responsible person candidate information evaluation、Application documents、business plan、AML and internal monitoring document preparation，and coordinate regulatory inquiries、Assurance and independent legal services。Final staff appointments、Professional opinions and licensing decisions are made independently by relevant persons and the China Securities Regulatory Commission.。
Hong Kong implements a simple and low tax system，In order to attract funds, the government，A clear profits tax exemption policy has been introduced for qualifying offshore funds and private equity funds。Manage overseas funds through Hong Kong No.9 license，Can effectively solve the onshore tax risks of overseas business income。
Corporations must maintain business registration and company secretarial services every year，Submission of annual return to the Registrar；Submit corporate income tax and employer tax returns to the tax office(56A/B)；and must hire an external auditor to audit the annual financial statements。
11. Hong Kong No. 9 Asset Management Financial License-Application Case
12. Relevant regulations、Regulatory information and further reading
| Data category | Related information |
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| Professional interpretation | |
| Legislation and regulatory guidance |
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| Licensing and regulatory authorities |
