Regulatory Alerts2026-09-03
Added · Updated
Circular on SFC-authorised funds with exposure to private market assets
Management companies of funds authorized by the Securities and Futures Commission (SFC) for public offering in Hong Kong must observe enhanced disclosure requirements for funds with direct or indirect exposure to private market assets. Their offering documents, including the key facts statement, must clearly disclose the extent and means of access of exposure, the nature and characteristics of the underlying private market assets, and associated key risks. A fund will be designated as a complex product if its total direct and indirect exposures to private market assets reach 50% or more of its net asset value, subjecting it to the SFC’s prevailing requirements for complex product sales, including suitability. Fund managers of existing funds are expected to review and update offering documents and communicate with distributors, while new funds may face closer SFC scrutiny.
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