Management Accountability at Registered Institutions

Our Ref: B1/15C
16 October 2017
The Chief Executive
All Authorized Institutions
Dear Sir/Madam,
Management Accountability at Registered Institutions I am writing to elucidate the expectations of the Hong Kong Monetary Authority (HKMA) with regard to management accountability at Registered Institutions (RIs) for conducting or supervising the conduct of businesses that constitute regulated activities (RAs). The guidance is set out in the form of frequently asked questions as attached. For the purpose of this guidance, “management” refers to (i) chief executives (CEs), including alternate chief executives (ACEs); (ii) directors 1 approved under section 71 of the Banking Ordinance (BO); (iii) managers notified to the HKMA under section 72B of the BO (or “section 72B managers”); (iv) executive officers (EOs) approved under section 71C of the BO; and (v) any other persons, not included in the above categories, involved in the management of any business that constitutes an RA for which the RI is registered. This guidance should also be read in conjunction with Supervisory Policy Manual (SPM) module SB-1 “Supervision of regulated activities of SFC-registered authorized institutions” 2 . SPM modules CG-1 “Corporate governance of locally-incorporated authorized institutions” and CG-2 “Systems of control for the appointment of managers” are also relevant. It is not the intention to duplicate the existing governance requirements on Authorized Institutions under the BO or to add an extra layer of requirements for RIs. This guidance does not change any approval or reporting requirements in relation to CEs, ACEs, directors, section 72B managers or EOs, or impose any additional regulatory obligations or legal liabilities on the management of 1 All references to “director” in this guidance apply to locally-incorporated RIs only. 2 “Circular to Licensed Corporations Regarding Measures for Augmenting the Accountability of Senior Management” issued by the Securities and Futures Commission (SFC) on 16 December 2016 is also of reference value.

RIs. Nonetheless, we see advantage in clarifying the HKMA’s expectations and enhancing the arrangements for gathering information on the RAs and individual businesses for which management of RIs are responsible. Under the guidance, relevant information on individual CEs, ACEs, directors and section 72B managers principally responsible for RA business should be submitted to the HKMA and the SFC. In addition, an organisation chart depicting the RI’s management and governance structure relevant to its RA business should be provided. To allow sufficient time for preparatory work, RIs are provided with six months for preparation and are expected to submit the required information by 16 April 2018. For applications of registration as an RI or addition of RA(s), applicants should also submit the required information to the HKMA in support of their applications, starting from the same date. We would also like to take this opportunity to remind that under Part IX of the Securities and Futures Ordinance (SFO), a person involved in the management of the business constituting any RA for which an RI is registered is a “regulated person” 3 , who is subject to the disciplinary powers under the SFO. Should you have any questions on the guidance, you may contact Ms Gloria Leung at 2878-1509 or Ms Katy Chan at 2878-8602. You may also approach your usual supervisory contacts at the Banking Conduct Department of the HKMA regarding implementation issues. Yours faithfully, Carmen Chu Executive Director (Banking Conduct) Encl. cc: The Hong Kong Association of Banks (Attn: The Chairman) The DTC Association (Attn: The Acting Chairman) SFC (Attn: Executive Director, Intermediaries) 3 Section 196(8)(c) of the SFO

---

Management Accountability at Registered Institutions Frequently asked questions Q1: In respect of management of Registered Institutions (RIs), what is the expectation of the Hong Kong Monetary Authority (HKMA) in identifying individuals as principally responsible for businesses that constitute regulated activities (RAs)? A1: Section 72B of the Banking Ordinance (BO) requires authorized institutions (AIs) to notify the HKMA of the appointments of managers (or “section 72B managers”) for the businesses and functions listed in the Fourteenth Schedule to the BO. It is however not a current practice to inform the HKMA of the businesses overseen by individual alternate chief executives (ACEs) or directors approved under section 71 1 , while chief executives (CEs) are clearly responsible for overall management of an AI, including its operations in conducting RAs as an RI. To better identify lines of responsibility and accountability within the institutions, RIs are expected to identify at least one individual as principally responsible for the overall management of the whole business of the RI (generally the CE) as well as managing each of the businesses or functions listed in paragraphs 2 to 8 of the Fourteenth Schedule to the BO, to the extent that these individuals are involved in the management of the business constituting any RA for which the RI is registered2 . In terms of seniority, such individuals are expected to be (i) CEs, including ACEs; (ii) directors approved under section 71 of the BO; or (iii) section 72B managers. Q2: Where directors are referred to in this guidance, do they cover non-executive directors (NEDs) and independent non-executive directors (INEDs)? A2: The HKMA does not expect NEDs and INEDs to be responsible for day-to-day management of RAs or other businesses, so they should not be regarded as “management” for the purposes of this guidance. However, the board of an AI (including an RI) has the ultimate responsibility for the operations and the financial soundness of the AI, including businesses that constitute RAs. 1 All references to “directors” in the guidance apply to locally-incorporated RIs only. 2 Where the RI regards an individual business as relatively small-scale within its overall business, it is acceptable to group more than one business under one such individual.

Q3: Are all CEs, ACEs, directors and section 72B managers of RIs required to seek approval to become Executive Officers (EOs)? A3: While these persons are often also EOs, the HKMA does not require CEs, ACEs, directors or section 72B managers to be all approved as EOs. This recognises the wide scope of businesses conducted by RIs, and that CEs, ACEs, directors and
section 72B managers are often responsible for general banking
businesses in addition to the conduct of RAs, and may not be responsible for direct supervision of RAs on a day-to-day basis. However, we remind RIs that, following the general principles set out in Supervisory Policy Manual (SPM) module SB-13 , it is already a requirement that any CEs, ACEs or directors who are directly responsible for supervising the conduct of RAs should be appointed as EOs in respect of the RA(s) they oversee4 and the HKMA may require individuals to become EOs if appropriate. RIs should also ensure that at least one of the EOs for a given RA should be a CE, ACE, director or section 72B manager. In addition, RIs should ensure that all EOs are not more than one rank below the CE, ACE, director or section 72B manager, if they do not themselves fall into these categories, so as to ensure that he or she has sufficient authority to conduct or oversee the relevant RA. Some flexibility may be allowed on exceptional basis subject to adequate justifications, where the HKMA will take into account the size of the RI, the significance of the RA in relation to the overall business of the institution, the management structure as well as the reporting line of the EOs. We also take this opportunity to remind that under Part IX of the Securities and Futures Ordinance (SFO), a person involved in the management of the business constituting any RA in RIs is “regulated person” 5 , regardless of whether or not he or she is registered as Relevant Individual (including EO), and is subject to the disciplinary powers under SFO. 3 SPM module SB-1 “Supervision of regulated activities of SFC-registered authorized institutions” 4 Please refer to paragraph 3.1.13 of the SPM module SB-1. 5 Section 196(8)(c) of the SFO defines “regulated person” as including “a person involved in the management of the business constituting any regulated activity for which a registered institution is or was (as the case may be) registered.”

Q4: How to determine whether an individual should be identified as principally responsible for a particular business or function? A4: To identify an individual as principally responsible for the overall management of the whole business of the RI as well as managing each of the businesses or functions listed in paragraphs 2 to 8 of the Fourteenth Schedule to the BO, to the extent that these individuals are involved in the management of the business constituting any RA for which the RI is registered, RIs are expected to take into account the individual’s seniority and authority within the RI6 . We expect such individuals to be CEs, ACEs, directors, or
section 72B managers.
Generally, the CE of an RI is principally responsible for the overall management of the whole business of the RI. For the remaining businesses or functions, a CE, ACE, director or
section 72B manager of the RI should be identified as principally
responsible 7
. For example, if an ACE is principally responsible for private banking under paragraph 2(b) of the Fourteenth
Schedule to the BO, he or she should be identified as principally
responsible for private banking to the extent that the private banking business constitutes one or more RAs, even though he or she may not be required to be appointed as a section 72B manager according to the requirements in SPM module CG-2. Another example is that a section 72B manager for institutional banking under paragraph 2(e) of the Fourteenth Schedule need not be identified as principally responsible for that function if the institutional banking business does not constitute any RAs. In exceptional cases where any RA conducted by an RI does not fall under the business areas managed by section 72B managers appointed for the areas listed in subparagraphs (a) to (f) of paragraph 2 of the Fourteenth Schedule to the BO, the business of such RA should be regarded as material to the RI and therefore covered by at least one section 72B manager. With regard to the functions listed in paragraphs 3 to 8 of the Fourteenth Schedule to the BO, it is considered that the roles of these functions, including but not limited to compliance, risk management and internal audit, are of no less importance than the 6 Reference can be made to the attributes set out in paragraph 2.3.3 of SPM module CG-2 “Systems of control for the appointment of managers”. 7 For the purpose of appointment of section 72B managers, if an individual is principally responsible for the conduct of a particular business or activity of an authorized institution but is also its director, CE or ACE, that individual does not fall within the definition of a manager (Footnote 4 of SPM module CG-2). Notwithstanding this, an RI should identify that person as principally responsible for a business or function listed in the Fourteenth Schedule to the BO for the purpose of this guidance.

front office roles with respect to RA business. For example, if more than one CE, ACE, director or section 72B manager are jointly responsible for a compliance function and one of them principally covers matters relating to RA business while the others cover those relating to non-RA business, the former (but not the latter) should be identified as principally responsible for the compliance function in relation to RAs. However, if the responsibilities of an individual overseeing such a function cover both RA and non-RA businesses, he/she should be captured for the purpose of this guidance. Q5: Is an ACE (in his/her capacity as acting CE) required to be identified as principally responsible for the overall management of the whole business of the RI? A5: No, so far as the ACE only acts for the CE who is precluded by illness or absence from carrying out his or her function on a temporary basis. Please also see Question 10 below. Q6: Are RIs required to identify a CE, ACE, director or section 72B manager as principally responsible for each key business line listed in paragraph 2 of the Fourteenth Schedule to the BO? A6: As illustrated in the example in the answer to Question 4 above, if a key business line of the RI does not constitute any RA business, it is not necessary for the RI to identify a CE, ACE, director or
section 72B manager as principally responsible for that business
line. However, this does not affect the requirement to notify the HKMA of the appointment of a manager under section 72B of the BO. Q7: Can an RI identify more than one individual as principally responsible for a particular business or function? A7: Yes. An RI may identify more than one CE, ACE, director or
section 72B manager for a particular function if more than one
individual is jointly principally responsible for that business or function.

Q8: Can an individual be identified as principally responsible for more than one business or function?
A8: Yes, if the individual is principally responsible for more than one business or function.
Q9: Does an individual identified as principally responsible for a function have to be an employee of an RI? Can an RI identify an independent third party to which a function of the RI is outsourced as principally responsible for that function? A9: It is not necessary for a person to be an employee of the RI as long as that person has sufficient authority within the RI and holds accountability for the function for which he or she is identified as principally responsible. For example, he or she can be an employee of the RI’s parent bank or group company, which supports a particular function, such as information technology or internal audit, of the RI. In cases where certain services or functions of an RI have been outsourced to an independent third party, the management of the RI should retain the ultimate accountability of the outsourced function. In this regard, we expect a member of the RI’s management, rather than an independent third party, should be identified as principally responsible for that outsourced function. Q10: Is an RI required to identify someone who is principally responsible for a business or function on a temporary basis only (e.g. to provide cover for a member of management who is precluded by illness or absence from carrying out his or her functions or to fill a position temporarily pending a permanent appointee)? A10: No, provided that the appointment is expected to last for no more than a few months and is not expected to be permanent. However, if a temporary appointment becomes permanent, the RI should notify the HKMA and the Securities and Futures Commission (SFC) of the change within 14 days.

Q11: Are persons identified as principally responsible for the overall management of the whole business of the RI as well as the businesses or functions listed in paragraphs 2 to 8 of the Fourteenth Schedule to the BO required to fulfil any fit and proper requirement? A11: We expect such persons to be CEs, ACEs or directors approved under section 71 of the BO or section 72B managers. Section 71 requires approval given by the HKMA, which should be satisfied that the person seeking such approval is fit and proper 8 , while an RI is required to put in place adequate systems of control to ensure that each section 72B manager should be a fit and proper person9 . As such, the fit and proper requirement is already covered by sections 71 and 72B of the BO and relevant SPM modules. Q12: How should RIs inform the HKMA on the relevant information about the individual businesses or functions for which management of RIs are responsible? A12: Relevant information on individual CEs, ACEs, directors and
section 72B managers principally responsible for RA business
should be submitted to the HKMA and the SFC using the forms at the Appendix. In addition, an organisation chart should be provided depicting the RI’s management and governance structure relevant to its RA business and showing the CE, ACEs, directors and section 72B managers identified for the purpose of this guidance and the RAs and individual businesses or functions for which they are responsible, as well as their respective reporting lines and the job titles of the persons reporting directly to them. The forms and organisation chart should indicate clearly the lines of responsibility and accountability for the conduct of RA business as well as the overall management of the whole business of the RI. Q13: Should RIs or the individuals concerned be responsible for the submission of information? A13: RIs, rather than the individuals concerned, should be responsible for submitting the relevant information to the HKMA and the SFC. RIs should ensure the accuracy and completeness of the information submitted and that each CE, ACE, director or 8 The relevant requirements are set out in the SPM module CG-1 “Corporate governance of locally-incorporated authorized institutions”. 9 The relevant requirements are set out in the SPM module CG-2 “Systems of control for the appointment of managers”.

section 72B manager has acknowledged his or her responsibility
for the particular business(es) or function(s) for which he or she is identified.
Q14: When will the information submission take effect?
A14: To allow sufficient time for preparatory work, RIs are expected to report the required information including organisation charts starting from 16 March 2018. The submission should be made to the HKMA and the SFC on or before 16 April 2018. Updates should be submitted to the HKMA and the SFC using the forms at the Appendix within 14 days of the change taking effect whenever there are any new appointments or cessation of appointments of individuals principally responsible for the relevant businesses or functions, changes in the personal particulars of the individuals, changes in the RAs or the businesses or functions for which the individuals are principally responsible, or changes in respective reporting lines. An updated organisation chart should be submitted along with the change except if it only involves a change of an individual’s personal particulars. Submissions should be made to the HKMA at RI_management_info@hkma.iclnet.hk and the SFC at mpra@sfc.iclnet.hk. In the event of an RI having any implementation issues, they may approach their usual supervisory contacts at the Banking Conduct Department of the HKMA. Q15: Are AIs applying for registration as an RI or existing RIs applying for addition of RA(s) required to provide the information set out in Question 12? A15: Starting from 16 April 2018, such applicants should submit to the HKMA the same information set out in Question 12 in support of their applications. Upon approval of the applications, the ongoing notification requirement outlined in Question 14 above should be followed.

---

Cover

Management Principally Responsible for Businesses that Constitute Regulated Activities
Nature of Submission:
Date of Submission:
Name of Registered Institution:
SFC Central Entity Number:
Contact Person
Name:
Post Title:
Department:
Telephone Number:
Email Address:
Note: 1. Please submit the completed form to the HKMA through the corporate STET email account at RI_management_info@hkma.iclnet.hk and the SFC at mpra@sfc.iclnet.hk. 2. Please state the FULL NAME of your institution in the subject of the email for ease of identification. 3. For corporate group involving two or more registered institutions, please submit the form for each institution in separate emails.

New Appointment

Management1 Principally Responsible for Businesses that Constitute Regulated Activities
New Appointment
Particulars of Individual	1				2				3				4				5				6				7				8
Full Name in English
	Surname	First	Middle		Surname	First	Middle		Surname	First	Middle		Surname	First	Middle		Surname	First	Middle		Surname	First	Middle		Surname	First	Middle		Surname
Full Name in Chinese
HK Identity Card Number
Passport Number2
Date of Expiry (dd/mm/yyyy)
Passport Issuing Country
HKMA Registration Number (if applicable)
SFC Central Entity Number (if applicable)
Place of Residence (Country/Region)
Job Title
Capacity3
Lines of Responsibility
Business(es) or Function(s) for which the Individual is Principally Responsible in respect of Regulated Activities4	Tick the box	Report to5	Type(s) of regulated activity	Effective date (dd/mm/yyyy)	Tick the box	Report to5	Types of regulated activities	Effective date (dd/mm/yyyy)	Tick the box	Report to5	Types of regulated activities	Effective date (dd/mm/yyyy)	Tick the box	Report to5	Types of regulated activities	Effective date (dd/mm/yyyy)	Tick the box	Report to5	Types of regulated activities	Effective date (dd/mm/yyyy)	Tick the box	Report to5	Types of regulated activities	Effective date (dd/mm/yyyy)	Tick the box	Report to5	Types of regulated activities	Effective date (dd/mm/yyyy)	Tick the box
Overall Management Oversight of the Whole Business of the Registered Institution
Fourteenth Schedule to the Banking Ordinance
Paragraph 2(a) - Retail Banking
Paragraph 2(b) - Private Banking
Paragraph 2(c) - Corporate Banking
Paragraph 2(d) - International Banking
Paragraph 2(e) - Institutional Banking
Paragraph 2(f) - Treasury
Paragraph 2(g) - Any Other Business which is Material to the Institution
Please Specify the Nature of Business [for paragraph 2(g)]
Paragraph 3 - Maintenance of Accounts or Accounting Systems
Paragraph 4 - Maintenance of Systems of Control for Risk Management
Paragraph 5 - Maintenance of Systems of Control for Anti-Money Laundering
Paragraph 6 - Development, Operation and Maintenance of Computer Systems
Paragraph 7 - Conduct of Internal Audits or Inspections
Paragraph 8 - Functions Ensuring Compliance with Laws, Regulations or Guidelines
1 Such individual is expected to be (i) chief executive/alternate chief executive, (ii) director approved under section 71 of the Banking Ordinance (BO), or (iii) manager notified to the Hong Kong Monetary Authority under section 72B of the BO. Please refer to the circular "Management Accountability at Registered Institutions" issued by the Hong Kong Monetary Authority on 16 October 2017.
2 Only applicable to non-Hong Kong permanent resident.
3 Chief Executive, Alternate Chief Executive and Director approved under section 71 of the BO and manager appointed under section 72B of the BO.
4To the extent that the individual is involved in the management of the business constituting any regulated activities for which the registered institution is registered.
5 Please state both the individual's reporting line(s) within your institution and within your group company, if applicable, in respect of the function(s) for which the individual is principally responsible.
6 Please use another form if there are more than 10 entries.

Table truncated: columns after the first 30 not shown.

Cessation of Appointment

Management1 Principally Responsible for Businesses that Constitute Regulated Activities
Cessation of Appointment
Particulars of Individual	1			2			3			4			5			6			7			8			9			10 3
Full Name in English
	Surname	First	Middle	Surname	First	Middle	Surname	First	Middle	Surname	First	Middle	Surname	First	Middle	Surname	First	Middle	Surname	First	Middle	Surname	First	Middle	Surname	First	Middle	Surname	First
Full Name in Chinese
HK Identity Card Number
Passport Number2
HKMA Registration Number (if applicable)
SFC Central Entity Number (if applicable)
Details of Cessation
Reason for Cessation
Effective Date (dd/mm/yyyy)
1 Such individual is expected to be (i) chief executive/alternate chief executive, (ii) director approved under section 71 of the Banking Ordinance (BO), or (iii) manager notified to the Hong Kong Monetary Authority under section 72B of the BO. Please refer to the circular "Management Accountability at Registered Institutions" issued by the Hong Kong Monetary Authority on 16 October 2017.
2 Only applicable to non-Hong Kong permanent resident.
3 Please use another form if there are more than 10 entries.

Table truncated: columns after the first 30 not shown.

Change of Particulars

Management1 Principally Responsible for Businesses that Constitute Regulated Activities
Change of Particulars/Responsibilities
Particulars of Individual	1				2				3				4				5				6 5
Full Name in English
	Surname	First	Middle		Surname	First	Middle		Surname	First	Middle		Surname	First	Middle		Surname	First	Middle		Surname	First	Middle
Full Name in Chinese
HK Identity Card Number
Passport Number2
HKMA Registration Number (if applicable)
SFC Central Entity Number (if applicable)
Details of Change	Please select the items to be changed and fill in the updated information.				Please select the items to be changed and fill in the updated information.				Please select the items to be changed and fill in the updated information.				Please select the items to be changed and fill in the updated information.				Please select the items to be changed and fill in the updated information.				Please select the items to be changed and fill in the updated information.
Full Name in English
		Surname	First	Middle		Surname	First	Middle		Surname	First	Middle		Surname	First	Middle		Surname	First	Middle		Surname	First	Middle
Full Name in Chinese
HK Identity Card Number
Passport Number2
Date of Expiry (dd/mm/yyyy)
Passport Issuing Country
Place of Residence (Country/Region)
Job Title
Business(es) or Function(s) for which the Individual is Principally Responsible in respect of Regulated Activities3	Tick the box	Report to4		Type(s) of regulated activity	Tick the box	Report to4		Type(s) of regulated activity	Tick the box	Report to4		Type(s) of regulated activity	Tick the box	Report to4		Type(s) of regulated activity	Tick the box	Report to4		Type(s) of regulated activity	Tick the box	Report to4		Type(s) of regulated activity
Overall Management Oversight of the Whole Business of the Registered Institution
Fourteenth Schedule to the Banking Ordinance
Paragraph 2(a) - Retail Banking
Paragraph 2(b) - Private Banking
Paragraph 2(c) - Corporate Banking
Paragraph 2(d) - International Banking
Paragraph 2(e) - Institutional Banking
Paragraph 2(f) - Treasury
Paragraph 2(g) - Any Other Business which is Material to the Institution
Please Specify the Nature of Business [for paragraph 2(g)]
Paragraph 3 - Maintenance of Accounts or Accounting Systems
Paragraph 4 - Maintenance of Systems of Control for Risk Management
Paragraph 5 - Maintenance of Systems of Control for Anti-Money Laundering
Paragraph 6 - Development, Operation and Maintenance of Computer Systems
Paragraph 7 - Conduct of Internal Audits or Inspections
Paragraph 8 - Functions Ensuring Compliance with Laws, Regulations or Guidelines
Effective Date (dd/mm/yyyy)
1 Such individual is expected to be (i) chief executive/alternate chief executive/director approved under section 71 of the Banking Ordinance (BO), or (ii) manager notified to the Hong Kong Monetary Authority under section 72B of the BO. Please refer to the circular "Management Accountability at Registered Institutions" issued by the Hong Kong Monetary Authority on 16 October 2017.
2 Only applicable to non-Hong Kong permanent resident.
3 Please provide all the businesses/functions for which the individual is principally responsible, to the extent that the individual is involved in the management of the business constituting any regulated activities. For instance, if there is additional responsibility, please indicate both the existing and new businesses/functions for which the individual is responsible. If there is reduction of responsibility, please indicate only the remaining businesses/functions for which the individual is responsible.
4 Please state both the individual's reporting line(s) within your institution and within your group company, if applicable, in respect of the function(s) for which the individual is principally responsible.
5 Please use another form if there are more than 6 entries.

Values

Last used Excel row number	305	NOTE: please mark the value field as unlocked in case new fields are added
cover_submtype_new	FALSE
cover_submtype_cessation	FALSE
cover_submtype_change
new_1_overall
new_1_2a_retail	FALSE
new_1_2b_private_banking	FALSE
new_1_2c_corp_banking
new_1_2d_intl_bank
new_1_2e_instutional_bank
new_1_2f_treasury
new_1_2g_any_other_biz
new_1_3_maint_account
new_1_4_maint_system_control
new_1_5_maint_aml
new_1_6_development
new_1_7_conduct_internal_audit
new_1_8_function_compliance
new_2_overall
new_2_2a_retail
new_2_2b_private_banking
new_2_2c_corp_banking
new_2_2d_intl_bank
new_2_2e_instutional_bank
new_2_2f_treasury
new_2_2g_any_other_biz
new_2_3_maint_account
new_2_4_maint_system_control
new_2_5_maint_aml
new_2_6_development
new_2_7_conduct_internal_audit
new_2_8_function_compliance
new_3_overall
new_3_2a_retail
new_3_2b_private_banking
new_3_2c_corp_banking
new_3_2d_intl_bank
new_3_2e_instutional_bank
new_3_2f_treasury
new_3_2g_any_other_biz
new_3_3_maint_account
new_3_4_maint_system_control
new_3_5_maint_aml
new_3_6_development
new_3_7_conduct_internal_audit
new_3_8_function_compliance
new_4_overall
new_4_2a_retail
new_4_2b_private_banking
new_4_2c_corp_banking
new_4_2d_intl_bank
new_4_2e_instutional_bank
new_4_2f_treasury
new_4_2g_any_other_biz
new_4_3_maint_account
new_4_4_maint_system_control
new_4_5_maint_aml
new_4_6_development
new_4_7_conduct_internal_audit
new_4_8_function_compliance
new_5_overall
new_5_2a_retail
new_5_2b_private_banking
new_5_2c_corp_banking
new_5_2d_intl_bank
new_5_2e_instutional_bank
new_5_2f_treasury
new_5_2g_any_other_biz
new_5_3_maint_account
new_5_4_maint_system_control
new_5_5_maint_aml
new_5_6_development
new_5_7_conduct_internal_audit
new_5_8_function_compliance
new_6_overall
new_6_2a_retail
new_6_2b_private_banking
new_6_2c_corp_banking
new_6_2d_intl_bank
new_6_2e_instutional_bank
new_6_2f_treasury
new_6_2g_any_other_biz
new_6_3_maint_account
new_6_4_maint_system_control
new_6_5_maint_aml
new_6_6_development
new_6_7_conduct_internal_audit
new_6_8_function_compliance
new_7_overall
new_7_2a_retail
new_7_2b_private_banking
new_7_2c_corp_banking
new_7_2d_intl_bank
new_7_2e_instutional_bank
new_7_2f_treasury
new_7_2g_any_other_biz
new_7_3_maint_account
new_7_4_maint_system_control
new_7_5_maint_aml
new_7_6_development
new_7_7_conduct_internal_audit
new_7_8_function_compliance
new_8_overall
new_8_2a_retail
new_8_2b_private_banking
new_8_2c_corp_banking
new_8_2d_intl_bank
new_8_2e_instutional_bank
new_8_2f_treasury
new_8_2g_any_other_biz
new_8_3_maint_account
new_8_4_maint_system_control
new_8_5_maint_aml
new_8_6_development
new_8_7_conduct_internal_audit
new_8_8_function_compliance
new_9_overall
new_9_2a_retail
new_9_2b_private_banking
new_9_2c_corp_banking
new_9_2d_intl_bank
new_8_2e_instutional_bank
new_9_2f_treasury
new_9_2g_any_other_biz
new_9_3_maint_account
new_9_4_maint_system_control
new_9_5_maint_aml
new_9_6_development
new_9_7_conduct_internal_audit
new_9_8_function_compliance
new_10_overall
new_10_2a_retail
new_10_2b_private_banking
new_10_2c_corp_banking
new_10_2d_intl_bank
new_10_2e_instutional_bank
new_10_2f_treasury
new_10_2g_any_other_biz
new_10_3_maint_account
new_10_4_maint_system_control
new_10_5_maint_aml
new_10_6_development
new_10_7_conduct_internal_audit
new_10_8_function_compliance
change_1_tick_fullname	FALSE
change_1_tick_chinese
change_1_tick_hkid
change_1_tick_passport
change_1_tick_place_residence
change_1_tick_job_title
change_1_tick_overall
change_1_tick_2a_retail
change_1_tick_2b_private_banking
change_1_tick_2c_corp_banking
change_1_tick_2d_intl_bank
change_1_tick_2e_instutional_bank
change_1_tick_2f_treasury
change_1_tick_2g_any_other_biz
change_1_tick_3_maint_account
change_1_tick_4_maint_system_control
change_1_tick_5_maint_aml
change_1_tick_6_development
change_1_tick_7_conduct_internal_audit
change_1_tick_8_function_compliance
change_2_tick_fullname
change_2_tick_chinese
change_2_tick_hkid
change_2_tick_passport
change_2_tick_place_residence
change_2_tick_job_title
change_2_tick_overall
change_2_tick_2a_retail
change_2_tick_2b_private_banking
change_2_tick_2c_corp_banking
change_2_tick_2d_intl_bank
change_2_tick_2e_instutional_bank
change_2_tick_2f_treasury
change_2_tick_2g_any_other_biz
change_2_tick_3_maint_account
change_2_tick_4_maint_system_control
change_2_tick_5_maint_aml
change_2_tick_6_development
change_2_tick_7_conduct_internal_audit
change_2_tick_8_function_compliance
change_3_tick_fullname
change_3_tick_chinese
change_3_tick_hkid
change_3_tick_passport
change_3_tick_place_residence
change_3_tick_job_title
change_3_tick_overall
change_3_tick_2a_retail
change_3_tick_2b_private_banking
change_3_tick_2c_corp_banking
change_3_tick_2d_intl_bank
change_3_tick_2e_instutional_bank
change_3_tick_2f_treasury
change_3_tick_2g_any_other_biz
change_3_tick_3_maint_account
change_3_tick_4_maint_system_control

Table truncated: rows after the first 200 not shown.