Concurrent SFC-HKMA thematic review of the distribution of non-exchange traded investment products

Circular
29 September 2025
Joint circular to intermediaries
Concurrent SFC-HKMA thematic review of the distribution of non-exchange traded investment products The Securities and Futures Commission (SFC) and the Hong Kong Monetary Authority (HKMA) will commence a new round of concurrent thematic review of the distribution of non￾exchange traded investment products by intermediaries. The 2024 SFC-HKMA joint product survey released1 in September 2025 showed that all major investment product types recorded significant sales growth last year, with collective investment schemes (CIS) rising by 76% year-on-year. The upcoming concurrent thematic review will examine selected intermediaries’ policies and procedures, systems and controls, and management oversight concerning the distribution of CIS. The objectives of this review include evaluating intermediaries’ compliance with the suitability requirement under the Code of Conduct2 , including their practices in performing product due diligence, conducting suitability assessments and providing information to clients. The SFC and the HKMA will share the findings of the upcoming concurrent thematic review with the industry and consider the need for further guidance where appropriate. Should you have any questions regarding the contents of this circular, please contact Ms Seine Luk at the Intermediaries Division of the SFC on 2231 1696 or Ms Hannah Wong at the Banking Conduct Department of the HKMA on 2878 8045. Intermediaries Division Banking Conduct Department Securities and Futures Commission Hong Kong Monetary Authority End SFO/IS/028/2025 HKMA/B1/15C

1 See the SFC-HKMA Joint Survey on the Sale of Non-exchange Traded Investment Products 2024. 2 Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission.