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。Broad range of investment targets，Includes equity、bond、derivatives、All types of assets including foreign exchange。
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 to the Securities and Futures Ordinance，The statutory business of a Type 9 license includes more than just securities or futures contract management，Also expressly covers the management of real estate investment plans。
virtual assets (VA) investment management
Ordinary No. 9 cards can invest in virtual assets not exceeding 10% of AUM。If you need 100% management of virtual asset funds，Additional application needs to be made to the SFC for upgrading to a “No. 9 license subject to virtual asset regulation”。
2. The legal definition of big 9 number plate vs small 9 number plate
Category A Small No. 9 license plate (not allowed to hold client assets)：Equivalent to mainland private equity。Separate accounts must be set up for customers，Assets cannot be kept on behalf of others。Only for "Professional Investors"(PI)”。Since fund funds are usually directly deposited into the custody account，This license is sufficient to meet the management needs of most overseas funds (such as Cayman SPC/ELP)。
Category B Ordinary No. 9 license plate (can hold customer assets)：Equivalent to mainland private equity。Customer assets can be directly transferred to the company account for unified management。Investors are still limited to “professional investors”(PI)”。Higher capital and compliance requirements。
Category C Public Offering Big 9 Cards (Top Big 9 Cards)：Equivalent to mainland public offering。Investors can include non-professional investors (retail investors)，Low starting amount，Can manage interactive funds such as ETFs。SFC has extremely strict capital and RO requirements for licensed corporations.。
Class D Virtual Asset No. 9：No matter big or small，To break through the 10% virtual asset AUM limit，All need to apply to SFC for upgrade.，Prove that it has the technical and risk control conditions to manage virtual asset business。
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 to directly supervise the proposed activities，At least one of them is an executive director，And at least one person shall stay in Hong Kong at all times to supervise。RO needs to have 5 years of relevant industry experience and relevant academic qualifications/qualifications。
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) |
|---|---|---|
| Small 9 cards：Subject to the licensing condition of "not to hold client assets" | not applicable (No hard requirements) | $100,000 Hong Kong dollar |
| Big 9 cards：Other situations (customer assets can be held) | $5,000,000 Hong Kong dollar | $3,000,000 Hong Kong dollar |
| SFC official application fee | Corporation application fee HK$4,740；Responsible person(RO) HK$2,950/person；licensed representative(LR) HK$1,790/person。 | |
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 (The total time taken is approx. 6-9 months)
1. Preliminary preparation (2-3months)：Determine the structure and register a Hong Kong company；Open a bank account；Leasing office and recruiting RO；Prepare all application forms and business plans。
2. SFC approval stage (4-6months)：Submit application and pay fees；Prepare exchange participant documents；Coordinate and participate in SFC meeting inquiries；Receive preliminary approval notice and supplementary materials；Finally officially issued the license。
[Path B] Merger and acquisition of licensed companies (The total time taken is approx. 3-6 months)
1. BVI holding structure mergers and acquisitions (about 3 months)：If the upper level of the original licensed company has a BVI offshore holding structure，Direct acquisition of BVI companies，Update SFC substantial shareholder filing，fastest。
2. Direct change of natural person shares (about 6 months)：If the original license is in the name of a natural person，A comprehensive major shareholder change application needs to be submitted to SFC，Re-examine the buyer’s financial and suitability qualifications，The time required is similar to applying directly。
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)
Provide one-stop all-inclusive service：Office rental included during license application period、RO recommendation matching (the application period salary is half discount of the market price, about HKD 30,000-35,000/month)、Prepared 150-page SFC form and commercial/AML compliance plan、Responded to multiple rounds of regulatory inquiries on behalf of、Provide lawyer notarization and legal opinions。
Assistance in mergers and acquisitions of licensed subject services
Screen clean targets through unique channels；Conduct 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.。This is equivalent to the Mainland’s private equity or public equity fund license。
Small 9 cards have the additional restriction of “not holding client assets”，No minimum paid-up share capital required，Only HK$100,000 in working capital is required，Low maintenance cost。In practice，Funds from overseas funds (such as Cayman SPC) are directly deposited into bank custody accounts，Asset management companies only issue trading orders and do not touch funds，Therefore, Xiao9pai fully meets the management needs of private equity funds.。
Xiao9pai has no equity requirement，100,000 working capital required，Only for professional investors(PI)。Ordinary Big 9 cards require 5 million share capital + 3 million working capital，Also PI only。The top public offering Big 9 cards not only need to meet the capital requirements of the big names，SFC has extremely high requirements for RO qualifications，However, funds can be raised from non-professional investors (retail investors)。
Can，But there are restrictions。Among funds managed by ordinary No. 9 license plates，The proportion invested in virtual assets shall not exceed 10% of the total AUM。If you want to break through 10% or even 100%, issue pure virtual asset funds，You must apply for an additional license upgrade from SFC，Prove that relevant technical and risk control conditions are available。
At least two ROs need to be appointed to oversee the asset management business，At least one of them must be an executive director and be resident in Hong Kong。The most important thing is，RO must prove that it has “discretionary asset management experience” (only doing investment research is not enough)，And must have at least 5 years of relevant industry experience and pass the HKSI exam。
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。
Register in company、Account opening、Submit to SFC after complete information，The approval period for licensed corporations is 15 weeks，RO approval takes 10 weeks。Including the time for defense and supplementary documents as a whole，Usually required 6-9 months。
Depends on architecture。If the top layer of the original licensed company is a BVI holding structure，You only need to change the BVI shareholders and file the change of major shareholder in SFC.，About 3 months at the fastest。If the license is held directly in the name of a natural person，The change process is similar to reapplying，Buyer qualifications need to be reviewed，It takes about 6 months。
Compared with the mainland，Hong Kong No. 9 plate investment targets have very few restrictions。Assets can be allocated globally，Invest in various overseas equity assets and derivatives，You can also use Shanghai-Hong Kong Stock Connect、Shenzhen-Hong Kong Stock Connect reverse investment in A shares。
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's one-stop all-inclusive service covers：Provide physical office leasing during the licensing period、Recommend matching RO candidates、Preparation of 150 pages of statutory forms and AML compliance reports、Fully authorized agent to respond to SFC’s multiple rounds of inquiries、Arrange for lawyers to notarize and issue legal opinions。
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。
