Since the Hong Kong Monetary Authority (“HKMA”), the People’s Bank of China (“PBoC”) and the Monetary Authority of Macao (“AMCM”) jointly announced plans to launch the Cross-boundary Wealth Management Connect in the Guangdong-Hong Kong-Macao Greater Bay Area (“Cross-boundary WMC”) last June, the regulatory authorities have been in close communication on the implementation details and pushed ahead with the preparatory work. In February this year, we entered into a Memorandum of Understanding with the regulatory authorities in the three places to establish the scheme’s supervisory cooperation arrangements and the liaison mechanism. We also conducted three rounds of industry consultation on the implementation details. Thanks to hundreds of questions and suggestions put forward by the industry, we were able to conceptualise possible implementation scenarios and thresh out implementation arrangements accordingly.
After many rounds of discussion and consultation, the HKMA, the PBoC and the AMCM promulgated today the implementation details of the Cross-boundary WMC applicable to the three places respectively. In the course of our discussion, we have endeavoured to provide banks and investors with as much flexibility as possible under the premise of proper risk controls. For example, banks are allowed to partner with more than one bank. We believe that such flexibility will facilitate the industry to develop the Cross-boundary WMC services. Residents in the Guangdong-Hong Kong-Macao Greater Bay Area (“GBA”) will be able to make cross-boundary investment via the Cross-boundary WMC in the next month or so at the earliest, after banks have completed relevant preparatory and reporting work. I would like to take this opportunity to share with you the key features of the Cross-boundary WMC.
As mentioned in the inSight article1 last June, we are guided by several principles when developing the Cross-boundary WMC: (i) meeting the actual needs of GBA residents; (ii) maintaining the respective regulatory regimes and practices on the Mainland and the two Special Administrative Regions; (iii) taking an incremental approach with proper risk controls; and (iv) protecting the legitimate interests of investors throughout the investment cycle. These principles are also reflected in the key features of the Cross-boundary WMC.
Account opening process
The Cross-boundary WMC is built with the banking systems in the two places in mind. Participating Hong Kong banks can partner with one or more banks on the Mainland to provide the Cross-boundary WMC services. They will be responsible for remittance and the distribution of wealth management products. For example, under the Northbound scheme, a Hong Kong investor needs to open a remittance account with a Hong Kong bank and an investment account with the corresponding Mainland partner bank. The two banks will pair the two accounts to ensure the closed-loop management of funds (please see below for details). While each bank may partner with more than one bank, each eligible investor can only maintain one Cross-boundary WMC remittance account in their place of residence and one Cross-boundary WMC investment account in the other jurisdiction.2
The account opening arrangements under the Cross-boundary WMC has been a topic of interest for both the industry and investors. As regards the Southbound scheme, Mainland residents may open accounts by attestation. Under the Northbound scheme, Hong Kong investors may open renminbi accounts following the prevailing rules and regulations or designate existing renminbi accounts as their investment accounts. We are also exploring with Mainland regulatory authorities on establishing arrangements for account opening by attestation under the Northbound scheme. The arrangements should take into account the existing practices, be implemented on a pilot basis and introduced in an incremental manner. In addition, under both the Southbound and Northbound scheme, after opening the accounts, investors may remotely operate their account and purchase eligible wealth management products through phone banking or online banking.
Eligible wealth management products
Taking into account factors such as investors’ general understanding of the wealth management products in each other’s market, product features and investors’ risk appetite, we will include relatively low risk and simple wealth management products as eligible products at the initial stage. Structured products or derivatives (e.g. futures and options) will not be included in the scope of eligible products at scheme launch.
Under the Northbound scheme, eligible products will include low- to medium-risk public funds and public fixed income wealth management products (which primarily invest in bonds and deposits) and equity wealth management products (which primarily invest in equities). Under the Southbound scheme, eligible wealth management products will include deposits (not including structured deposits), Hong Kong domiciled funds authorised by the Securities and Futures Commission and bonds which are assessed as low- to medium-risk and non-complex.
At the initial stage, the Northbound and Southbound schemes will each be subject to an aggregate quota of RMB 150 billion and an individual investor quota of RMB 1 million. The usage of the quota is calculated on a net cross-boundary remittance basis. For example, if a Northbound investor remits RMB 800,000 from Hong Kong to the Mainland to purchase wealth management products, his or her individual investor quota usage will be RMB 800,000. If the investor subsequently sells part of the investment and remits some of the gains and principal, say RMB 200,000, back to Hong Kong, his or her individual investor quota usage will be RMB 600,000 (i.e. RMB 800,000 - RMB 200,000 = RMB 600,000). When the quota is reached, cross-boundary remittance to the individual investment account will be suspended. However, remittance from the investor’s investment account to his or her remittance account will not be affected. Going forward, we will review the overall usage of quota and market developments from time to time, and explore the need for adjustment with the Mainland and Macao regulatory authorities.
Under the Cross-boundary WMC, cross-boundary remittance needs to be conducted in renminbi via the Cross-border Interbank Payment System. After completing the account-opening process, investors may start to make cross-boundary RMB remittance to their investment accounts. Under the Southbound scheme, Mainland investors who are interested in investing in products denominated in other currencies can convert their RMB funds into the relevant currencies in Hong Kong’s offshore market. Under the Northbound scheme, Hong Kong investors can first obtain RMB funds in Hong Kong’s offshore market before remitting the funds to their investment accounts on the Mainland. It is also worth noting that the Northbound scheme will not be subject to the existing daily RMB remittance limit of RMB 80,000 for Hong Kong residents.
Funds in the Cross-boundary WMC accounts will be subject to closed-loop management. Investors’ funds in their investment accounts can only be used for the purchase of eligible wealth management products and they must be remitted to the investors’ remittance accounts via the same path upon investment exit. Investors are not allowed to withdraw cash from their investment accounts or remit funds from their investment accounts to any accounts other than their remittance accounts.
Cross-boundary distribution arrangements
Since in the initial stage the scheme’s investable universe will be relatively low-risk and simple wealth management products distributed by banks, it is appropriate for such distribution to be conducted under an “execution-only” model. Under such a model, investors will initiate and directly issue investment instructions, and banks will execute such instructions. When in doubt, investors may make an enquiry to the distributing banks, which may provide factual information about the Cross-boundary WMC or about eligible wealth management products in response. When customers are physically present in the jurisdiction of the distributing bank, the bank may perform sales activities and provide investment advice in accordance with the existing laws, regulations and supervisory guidance.
Investor protection is an important consideration for the Cross-boundary WMC. To ensure that the rights and interests of investors are protected by the relevant laws and regulations, all complaints and illicit activities will be handled in accordance with the principle of territorial administration. Let us take the Northbound scheme as an example. Mainland banks will handle complaints involving wealth management products and relevant investments in accordance with the prevailing mechanism and under the supervision of Mainland regulatory authorities, while Hong Kong banks will handle complaints involving cross-boundary remittance under the supervision of Hong Kong regulatory authorities; and vice versa for the Southbound scheme. We will require banks to explain these arrangements clearly before investors enter into any investments and provide channels for customers to lodge and follow up on complaints across the boundary.
Thanks to the concerted efforts of various regulatory authorities and the constructive suggestions of the industry, we have established a robust policy framework for the Cross-boundary WMC. We believe that the Cross-boundary WMC can provide investors with a greater variety of wealth management products, further facilitate cross-boundary investment and create new opportunities for the financial industry in Hong Kong. We will closely monitor the operation of the Cross-boundary WMC and draw lessons from the operating experience. We will also keep a close dialogue with the industry and roll out enhancement measures as and when appropriate.
Deputy Chief Executive
Hong Kong Monetary Authority
10 September 2021
2Under the Southbound scheme, Mainland investors may maintain one Cross-boundary WMC investment account in Hong Kong and one in Macao.