1. [Statutory Classification and Regulatory Dividends] of Japan’s “Investment Assistance and Agency Industry”
Core investment advisory business
Based on investment advisory contract，Providing substantive advice on "value of securities" or "value analysis of financial instruments"。According to the law, there is no right to execute investments and make decisions on financial management on behalf of clients.。
Agents and Media (intermediary) business
Allowed as an independent intermediary，Between overseas parent companies or asset management platforms and Japanese local customers，Legal agent or media signs "investment contract"。
Zero capital threshold and organizational exemption
There are no minimum capital and net asset bottom line requirements according to law。It is not mandatory to establish a board of directors or assign supervisors and other complex corporate governance institutions.，Very low entry and maintenance costs。
FMEO full English access channel
FSA opens Financial Markets Access Office (FMEO)。Affiliated institutions with similar overseas licensing experience，Prior consultation can be conducted in English throughout the process in accordance with the law.、Case file submission and daily regulatory inquiries。
2. Industry information：[Case of Legally Approved Representatives of Foreign Asset Management Institutions in Japan]
Impact investing organization：AIM
Affirmative Investment Management Japan 于 2021 Passed FMEO all-English one-stop service channel，Quickly complete the legal registration of "Investment Assistance·Agency Industry"。
Global active asset management：Columbia Threadneedle
At 2021 Year 8 Passed FMEO and was approved to register for "Investment Assistance·Agency Industry"，Later in 2022 Year 8 In March, we further obtained the "Second Financial Product Trading Industry" license in accordance with the law.。
Global Alternative Asset Management：Algebris
Focus on Japanese distribution business，At 2019 Year 3 Successfully registered two licenses: "Investment Assistance Agency Industry" and "Investment Utilization Industry" at the same time，and obtain legal subsidies for the Tokyo Metropolitan Operation Base in accordance with the law.。
Pan-European Investment Company：Tithe
Take advantage of the Tokyo Metropolitan Government’s financial one-stop support services，At 2019 Year 12 Completed the registration of "Second Financial Business Law" and "Investment Assistance and Agency Industry" in 2018，Accelerate sales to Japanese institutional investors。
3. [Statutory capital and fee requirements] for Japanese investment advisory licenses
| Review feature categories | Legal standards and practical payment amounts |
|---|---|
| Legal capital and net assets | No mandatory minimum (0 Yen requirements）。Significantly different from what must be maintained in the investment and utilization industry 5,000 Bottom line of net worth of 10,000 yen。 |
| Business margin (Escrow deposit) | The full amount must be paid to the Japanese Legal Affairs Bureau in accordance with the law. 5,000,000 Japanese yuan (500Ten thousand yuan) A business deposit as a prerequisite for business development。 |
| Government registration license tax | When submitting a formal registration application，must be paid to the tax office 150,000 Japanese yuan (15Ten thousand yuan) Registration fee。(Note：If you are a financial intermediary, it is 90,000 yen)。 |
4. [Corporate governance and qualifications under the FSA (Fit & Proper) Review standards]
Physical essence and representative in Japan：Must have a physically independent and exclusive business office in Japan，Virtual offices and shared workstations are strictly prohibited。If it is a foreign legal person，Must appoint at least one permanent representative with a Japanese address。
Executive Compliance Bottom Line：Operators and managing directors must fully understand the Financial Services Law and internal governance requirements，No license suspension or criminal conviction within five years，Absolutely no connection with violent gangs (gangsters)。
Investment advice specialist：Required 1 name or 2 More than 100 full-time business personnel with extensive knowledge and experience in value analysis of securities or financial instruments (in practice, at least 1 Relevant resume for more than 10 years)。
Independent Compliance Officer (Compliance Officer)：Must be equipped with sufficient compliance knowledge and experience (usually review 1 Personnel with more than 20 years of compliance guidance experience)，In principle, absolute organizational independence from the sales and investment departments must be maintained。
5. [Statutory Registration Document Review Checklist] submitted to the Finance Bureau and FMEO
| File category | Submission details of statutory requirements and interpretation of regulatory key points |
|---|---|
| Basic corporate and senior management due diligence | Company Articles of Association and Certificate of Registration Matters。Resumes of all senior executives and key employees、Resident certificate (overseas residents can substitute a sworn statement)、No bankruptcy certificate and personal compliance oath。 |
| Business Operation and Prevention of Conflicts of Interest | Registration application form、Business content and method instructions。Description of business execution system (with detailed organizational and personnel structure chart)、Seat allocation plan to demonstrate physical distancing)。Description of the status of specific related parties (parent and subsidiary)。 |
| Financial and Internal Control Documents | The latest balance sheet and income statement (including income and expenditure forecast for the previous two years)。If you do not join an industry association，A draft of the "Internal Corporate Rules" that is equivalent to JIAA must be submitted in accordance with the law.。 |
6. [Statutory Application and FSA Preliminary Procedures] for Japanese Investment Advisory License
first stage：Prior consultation and summary review (about 3-4 months)
Submit Summary Letter with local finance bureau or FMEO。Regulators go through multiple rounds of interviews，Substantive pre-trial business model、Personnel isolation and internal control system。
second stage：Formal application and fee payment
After prior consultation and confirmation，Formally submit a large number of application documents and pay to the tax bureau 15 Ten thousand yen registration is exempt from tax (foreign investors who meet the conditions can use English throughout the process)。
The third stage：Legal standards review (legal 2 months)
The legal standard review processing time for new registrations is 2 months。This cycle does not include time-consuming requests from regulatory agencies to supplement or modify materials.。
Stage 4：Association membership and ADR docking (about 1-2 months)
After receiving the registration notice，Apply to join the Japan Investment Advisory Industry Association (JIAA)，and complete statutory financial alternative dispute resolution (ADR / FINMAC) Mechanism docking。
The fifth stage：Business deposit deposit and business development (total cycle 6-12 months)
Deposit with Legal Affairs Bureau 500 Ten thousand yen business deposit。All qualification reports and internal controls have been completed，Only institutions can sign investment advisory contracts in accordance with the law.。
7. realist regulation、Dispute Resolution and [Legal Compliance Red Line]
Strictly prohibit red lines in financial management services on behalf of clients：Investment advice license is limited to providing advice。If investment execution authorization (discretionary authorization) is obtained from the client，That is a serious transgression，Must apply for an "investment and utilization industry" license with extremely high threshold。
Substantive audit without joining the association：If you do not join a self-regulatory organization such as JIAA，Internal regulations must be formulated with equivalent force。In practice，Businesses that are not members will face the FSA’s more stringent compliance system regular inspections and written audits。
False advertising and document delivery penalties：It is strictly prohibited to use misleading words such as "sure to make money" in advertisements。Failure to issue the "written document delivered before contract conclusion" to the customer in accordance with the law，Will face severe official business improvement and suspension penalties。
No regular renewal but facing revocation at any time：There is no fixed validity period for Japanese Goldsmiths’ Law License。But the FSA implements "realism" to continue supervision。Executives who commit violations or “failure to ensure adequate performance of their business” will have their licenses revoked.。
8. [Industry association fees and government subsidies] for Japanese investment advisory licenses
| Funding and Expense Categories | Statutory fee standards and official subsidy benchmarks (JPY) |
|---|---|
| Industry associations (JIAA) fees | Japan Investment Consultants Association membership fee 1,000,000 Japanese yuan。Annual fees are paid in proportion to operating income，legal lower limit 40 Ten thousand yuan，upper limit 800 Ten thousand yuan。 |
| FSA and Tokyo Metropolitan Government Fund Subsidy | Foreign-funded institutions can apply for reimbursement of office rent during the initial period of establishment.、Human resources recruitment and legal compliance consulting fees，The reimbursement rate is up to 70% (the maximum limit is up to 2,000 Ten thousand yuan）。 |
| specific immunity channel (Special case filing) | If fund investors only include 1 qualified institutional investor (QII) and no more than 49 specific investors，or overseas investment exceeds 50%，Only required by law Prior filing (Notification)，Exemption from full license。 |
9. Hong Kong Huitong's legal agency service for the entire Japanese investment advisory license case
Physical establishment and physical office implementation
Apply for Japan Co., Ltd. (KK) register。Provide legal physical office space with exclusive independent access control，Match representatives and compliance officers in Japan who meet the FSA’s eligibility review in accordance with the law。
Compilation of core legal documents and procedures
Write "Registration Applicant Summary Letter"。Compilation includes customer isolation、"Business Method Book" and Compliance Risk Control Procedures for Conflict of Interest Prevention，Physical isolation structure of planning department (seating map)。
FMEO interview coaching and subsidy application
Coach senior executives to participate in pre-advisory interviews。Fully authorized FMEO full English channel case file submission and written inquiry defense，Assist in handling the withdrawal and deposit of trust funds from the Legal Affairs Bureau、JIAA membership and Tokyo landing subsidy application。
10. Japanese investment advice and agency industry license core legal questions and answers (FAQ)
divided into：The First/Second Financial Business Law Industry、Investment and application industry、Investment advice and agency industry。If only investment advice is provided based on analysis of the value of securities，Do not manage finances on behalf of customers or touch funds，Just apply for "Investment Assistance and Agency Industry"。
The law does not stipulate minimum capital and net assets。However, it must be paid to the tax bureau according to law 15 Registration tax of 10,000 yen，and deposit it with the Legal Affairs Bureau before business commences. 500 A business deposit of 10,000 yen is required to legally start a business.。
Absolutely prohibited。Must establish a physically independent and exclusive actual business office in Japan (virtual or shared offices are strictly prohibited)。Foreign legal persons must designate a permanent representative with a Japanese domicile in accordance with the law。
Investment advice specialists must have extensive practical experience in securities analysis (usually review at least 1 years and above)。The person in charge of compliance must have sufficient legal compliance knowledge and practical guidance experience。
Concurrent positions are strictly prohibited。In principle, the compliance officer must maintain absolute independence from the sales and investment departments in terms of organizational structure.。Even if the business is small，It is also necessary to ensure that the personnel structure can conduct independent compliance reviews to prevent conflicts of interest.。
It is possible if special conditions are met。If you already have similar licensing experience overseas，Available through the Financial Markets Access Office (FMEO)”Enjoy pre-consultation in English、Continuous supervision after case file submission and licensing，No need for Japanese translation。
The first phase of the pre-trial interview usually requires 3 to 4 months。After the formal submission of the application in the second stage，The statutory processing period for new registrations is 2 Months (absolutely not including the time spent on correcting materials)。The total cycle is conservatively estimated to be more than half a year。
A "Business Method Statement" must be submitted、Description of organization and business execution system、Executive No-Bankruptcy Affidavit、Latest balance sheet and income statement，and office floor plans and seating plans demonstrating physical independence。
Not legally required to join。But if you don’t join associations such as JIAA，Applicants must formulate "internal rules" that are equivalent to the association's articles of association。In practice, those who are not members will face extremely stringent compliance audits by the FSA.，The vast majority of businesses choose to join the membership。
Once the license is approved, it has no fixed validity period.，No regular license renewal required。But the FSA implements "realism" to review at any time，False advertising occurs、Documents are not delivered in accordance with the law or there is a lack of awareness of compliance，Face business suspension and revocation penalties at any time。
have。If domestic investors only include 1 “Qualified Institutional Investors” (QII)"and no more than 49 specific investors，Or the proportion of overseas investment exceeds 50%，According to the law, only a prior filing is required to be submitted to the supervisory authority (Notification)。
Can。FSA and Tokyo Metropolitan Government set up special subsidies for overseas asset management institutions，The reimbursement rate is up to 70% of the actual expenses (the upper limit is up to 2,000 10,000 yuan)，Covers office rent、Recruitment fees and external expert consultant fees for licensing applications。
