Global Trustee and Fiduciary Services Bite Sized Issue 10 2025

10 QUICK LINKS FINTECH MIFID II/MIFIR OPEN FINANCE SUSTAINABLE FINANCE/ESG T+1 ASIA AUSTRALIA EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 10 | 2025 SFC Consults on Extending Investor Identification Regime to Exchange-traded Derivatives in Hong Kong On 22 September 2025, the SFC launched a consultation on the proposed investor identification regime for the exchange-traded derivatives market (HKIDR-DM) to further bolster the integrity and sustainable development of Hong Kong’s capital markets. The SFC says that, building upon the successful implementation of a similar regime for the securities market (HKIDR-S) since March 2023, the proposed HKIDR-DMwould cover on- exchange orders for futures contracts, options contracts and stock options traded through the Hong Kong Futures Exchange Limited’s trading system. The SFC says HKIDR-DMwould adopt a model like that of the HKIDR-S, under which licensed corporations and registered institutions offering brokerage services or conducting proprietary trading would be required to submit clients’ names and identity information to a centralised data repository. The consultation period ends on 22 December 2025. The SFC says the proposed regime is expected to be implemented in the first quarter of 2028. Link to Consultation here SGX RegCo Streamlines ETF Designated Market-maker Requirements On 5 September 2025, the Singapore Exchange Regulation (SGX RegCo) published a consultation seeking market feedback on proposed changes to streamline the requirements of designated market-makers (DMMs) for exchange-traded funds (ETFs). SGX RegCo says it intends to remove administrative requirements for notification and announcement when ETF DMMs cease, or resume, bid and offer quotations. This aims to bring SGX practices in line with those of other global markets. The proposals result from a review of the regulatory framework around the trading of ETFs to identify areas that may impact the listing and trading of ETFs. This follows the Monetary Authority of Singapore’s enhancement in July 2025 of the Grant for Equities Market Singapore Scheme for ETFs to facilitate more ETF listings. The consultation period closed on 26 September 2025. Link to Consultation here SFC-HKMA Joint Survey Shows Record Investment Product Sales andMarket Participation in2024 On 4 September 2025, the SFC and HKMA published the findings of their annual joint survey on the distribution of non-exchange-traded investment products, showing record sales and level of market participation for these products during 2024. Total transaction amount of non-exchange-traded investment products by licensed corporations (LCs) and registered institutions (RIs) surged 40% year-on-year to a record HKD 6,073 billion in 2024. Market participation also witnessed broad-based growth last year. The number of firms engaged in the sale of investment products grew by 9% to a new high of 414, with an overwhelming 46%more than doubling their sales year-on-year. The number of large firms saw a 12% increase to 101. The SFC and HKMA state that all major investment product types recorded significant sales growth in 2024. Sales of authorised collective investment schemes (CIS) grew 96% to HKD 1,400 billion and unauthorised CIS grew 50% to HKD 844 billion. Sales of structured products and debt securities increased by 30% and 29% year-on-year, respectively. Equity-linked products thrived amidst strong market momentum and remained the top-selling structured product category with sales of HKD 1,729 billion, up 43% year-on-year. Meanwhile, money market funds and sovereign bonds remained attractive to investors due to their perceived lower risks and decent returns under the prevailing high-interest rate environment in 2024. The survey showed an increase in the sales of money market funds, which accounted for 80% of the total transaction amount of the top five CIS reported by the large firms, up from 76% in 2023.

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