Proposal for Enhancing the Development and Regulatory Framework of the Securities, Futures, Asset Management, and Virtual Asset Industries
Release Date: 2023-08-01
2 Tim Mei Avenue, Tamar, Hong Kong
Government Headquarters, 24th Floor
Financial Services and the Treasury Bureau
Government of the Hong Kong Special Administrative Region of the People's Republic of China
To: The Government of the Hong Kong Special Administrative Region of the People's Republic of China
Financial Services and the Treasury Bureau
Mr. Christopher Hui, Secretary
Mr. Joseph Chan, Under Secretary
Proposal for Enhancing the Development and Regulatory Framework of the Securities, Futures, Asset Management, and Virtual Asset Industries
Dear Secretary Christopher Hui and Under Secretary Joseph Chan,
1. Introduction
1.1 Recent developments such as (1) Indonesia surpassing Hong Kong in IPOs to become the fourth-largest globally; (2) the market value of a single American company, Apple, equaling two-thirds of Hong Kong's total market value (as of July 4, 2023); and (3) the trading volume of Tesla in the U.S. being 2.86 times that of Hong Kong's entire market highlight significant challenges.
1.2 The Hong Kong securities, futures, and asset management industries (hereinafter referred to as "the industries") have been under regulatory and structural review since the 2008 "subprime crisis" triggered the "Lehman Brothers mini-bond incident." Then-Financial Secretary John Tsang directed the Hong Kong Monetary Authority and the Securities and Futures Commission (SFC) to conduct internal reviews and propose strengthening measures. However, these actions primarily focused on banking and brokerage sales practices and led to a series of suitability requirements, rather than a comprehensive review of developmental and regulatory mechanisms.
1.3 Looking back over decades, regulatory laws for the securities and futures industries were established a year after the 1973 stock market crash. Two non-permanent committees were created to oversee securities and commodities trading. Following another crash in 1987, a committee led by chartered accountant Mr. Ian Hay Davison reviewed the organizational, regulatory, and operational aspects of the relevant government departments, leading to the "Davison Report." The report, published in May 1988, recommended creating a new market regulatory body outside the civil service structure, which eventually became today's SFC.
1.4 Post the 1998 Asian financial crisis, a review led to the consolidation of previous securities and futures market regulations, culminating in the Securities and Futures Ordinance effective April 1, 2003.
1.5 Following the 2002 "penny stocks incident," then-Financial Secretary Antony Leung commissioned a review by Mr. Robert Kotewall and Mr. Gordon Kwong. The resulting "Penny Stocks Incident Report" expressed doubts about the existing three-tier organizational structure's effectiveness in fulfilling its functions.
1.6 The SFC was established to protect small investors' interests, maintain and promote fairness, efficiency, competitiveness, transparency, and order in the securities and futures industries. It was not tasked with development functions, focusing solely on regulation.
1.7 The Financial Development Council, not a government department but a limited company established by the government, lacks actual authority.
1.8 There is no authoritative body in Hong Kong specifically dedicated to the development of the industries, including InvestHK and the Hong Kong Trade Development Council.
2. 2022 Profit Data of Hong Kong Securities Dealers
According to the SFC's “Financial review of the securities industry” for the year ending December 31, 2022, the net profit of Hong Kong securities dealers was HKD 22.866 billion, a 65% decrease from the previous year.
3. Current Development Authority for the Hong Kong Securities Industry
3.1 Responsibilities of the Financial Secretary
The government traditionally adheres to a “positive non-interventionism” policy, rarely directly guiding industry development. According to the "Responsibilities of the Financial Secretary and the Secretary for Financial Services and the Treasury" announced by the Chief Executive on June 27, 2003:
(2) The Financial Secretary is responsible for:
(a) Monetary System;
(b) Exchange Fund;
(c) Public Finance;
(d) Financial System; and
(e) Hong Kong's status as an international financial center.
(4) Regarding public finance, the financial system, and Hong Kong's status as an international financial center, the Financial Secretary sets macro policy objectives, while the Secretary for Financial Services and the Treasury formulates specific policies to achieve these goals and implements them through regulatory bodies and other organizations.
In February 2003, the Financial Regulatory Council was established, chaired by the Secretary, with the aim of enhancing the efficiency and effectiveness of regulation and supervision of financial institutions in Hong Kong, promoting the development of financial markets, and helping to maintain market stability. Its members include representatives from the Hong Kong Monetary Authority, the Securities and Futures Commission, the Insurance Authority (“IA”), the Mandatory Provident Fund Schemes Authority, the Accounting and Financial Reporting Council, and the Financial Services and the Treasury Bureau. However, there have been no public meeting records available to date.
3.2 Responsibilities of the Secretary for Financial Services and the Treasury
As outlined in the "Responsibilities of the Financial Secretary and the Secretary for Financial Services and the Treasury":
(5) Therefore, the primary responsibility of the Secretary for Financial Services and the Treasury is to ensure the effective implementation of the specific policies mentioned in paragraph 4. In fulfilling these duties, he should liaise with and seek advice from relevant internal and external parties. As the custodian of these policy areas, the Secretary should keep the Financial Secretary informed of any matters that may require action under the statutory or other powers entrusted to the Financial Secretary. When exercising these powers, the Financial Secretary may, when deemed appropriate, seek the advice of the Secretary for Financial Services and the Treasury.
The responsibilities of the Secretary and the Director, as outlined in sections 2.1 and 2.2, primarily focus on "formulating specific policies" as mentioned in paragraph 4. However, there is no explicit mention of responsibilities related to leadership and development within the industry.
In February 2003, the Financial Market Stability Committee was established, chaired by the Secretary, with the goal of emphasizing the importance of stabilizing Hong Kong's financial markets. Members include representatives from the Hong Kong Monetary Authority, the Securities and Futures Commission, and the Insurance Authority. However, there have been no public meeting records available thus far.
The Financial Services and the Treasury Bureau's Financial Services Branch is the department that oversees the securities industry.
The Financial Services Branch of the Financial Services and the Treasury Bureau governs the securities industry, with a budget of HKD 760.7 million for 2023/24 and a staffing establishment of 109 positions as of March 31, 2023. This allocation is mismatched with the scale of the Hong Kong securities industry.
The funding and staffing allocation is simply not commensurate with the scale of Hong Kong's securities industry.
3.3 Responsibilities of the SFC
Founded to protect small investors and promote fairness, efficiency, competitiveness, transparency, and order in the securities and futures industries, the SFC lacks developmental functions, focusing solely on regulation. The SFC has not requested funding from the Legislative Council since 1993-94, funding itself through market levies.
For 2023-24, the budgeted revenue is HKD 1.90817 billion, with operating expenses of HKD 2.47448 billion. The SFC proposes adding four new positions, totaling 1,022 staff.
3.4 Responsibilities of the Hong Kong Exchanges and Clearing Limited (HKEX)
As a listed company in Hong Kong, HKEX aims to develop its business but is not a driver for industry development.
3.5 Responsibilities of InvestHK
InvestHK, a department under the Commerce and Economic Development Bureau, promotes foreign direct investment and assists Mainland China, Taiwan, and overseas enterprises in establishing and expanding in Hong Kong, fostering long-term partnerships.
InvestHK's fields include:
1. Business and Professional Services;
2. Creative Industries;
3. Financial Technology;
4. Innovation and Technology;
5. Transportation, Infrastructure, and Advanced Manufacturing;
6. Consumer Products;
7. Information and Communications Technology;
8. Tourism and Hospitality;
9. Financial Services.
With a 2023/24 budget of HKD 278.2 million and 40 positions as of March 31, 2023, the scope of its work raises concerns about meeting industry needs effectively, given its affiliation with the Commerce and Economic Development Bureau rather than the Financial Services and the Treasury Bureau and the breadth of its nine fields, including financial services.
However, (1) being under the Commerce and Economic Development Bureau instead of the Financial Services and the Treasury Bureau, whether it can effectively implement the industry's timely needs becomes a problem. (2) There are nine different domains, and "financial services" includes banking, foreign exchange, insurance, securities, futures, virtual assets, asset management, and so on.
To put it bluntly, with only 40 positions tasked with overseeing 9 different business domains, how can they adequately cater to the needs of the securities industry? The funding and staffing allocation is simply not commensurate with the scale of Hong Kong's securities industry.
3.6 Responsibilities of the Hong Kong Trade Development Council (HKTDC)
The Trade Development Council (TDC) falls under the Commerce and Economic Development Bureau, and is responsible for promoting, assisting and developing Hong Kong's trade. Its departments include:
(1) Exhibition and Digital Business
(2) Communications and Promotion
(3) Research
(4) Commodity Trade and Innovation
(5) Services Promotion
The last two departments are involved in financial services.
The budget allocation for the 2023-24 fiscal year is HK$640.2 million, but there are no data on the number of staff.
However, based on general observation, the Trade Development Council is not heavily involved in promoting the securities industry.
3.7 In summary, based on the above 6 points, the Hong Kong securities industry and its market capitalization do not have a dedicated department specifically managing the development of the securities industry. The budget for the Financial Services Branch under the Financial Services and the Treasury Bureau is HK$253.6 million (out of a total budget of HK$760 million for the bureau, with 3 deputy secretaries, of which the securities industry is one-third, i.e. HK$253.6 million). Adding the HK$30 million budget for the Investment Promotion Agency (out of a total budget of HK$278.2 million for 9 business areas), the total budget comes to HK$283.6 million. This is only about 1% compared to the HK$22.866 billion net profit of Hong Kong securities dealers in 2022. If compared to 2021, it is only 0.4%. The involvement in terms of manpower and budget is shockingly disproportionate!
3.8 However, the SFC, a regulatory body, has expenditures of HKD 2.47448 billion and a staffing total of 1,022, ten times that of the aforementioned departments.
4. Advantages and Disadvantages of the Three Major Global Financial Regulatory Frameworks
4.1 Globally, regulatory systems aim to: (a) reduce systemic risk; (b) maintain safety and soundness; (c) protect investors' interests; and (d) ensure market fairness.
4.2 The three main regulatory systems are:
(a) Segregated Model: Hong Kong, along with many other places, adopts the sectoral regulatory model, which is the most common regulatory system globally. It is relatively simple and can save a lot of administrative costs, with independent regulators overseeing single industries and handled by experts. This system is often further strengthened with more cross-sector coordination after financial crises.
However, the advantage of this model is also its drawback. Since the regulatory bodies only focus on regulatory matters, they do not handle industry development. In order to demonstrate that their regulated sectors have no regulatory flaws, the regulators may gradually shift towards an overly stringent regulatory approach, without properly balancing the needs of industry development.
Examples: Mainland China, Portugal, Spain, Israel.
(b) Integrated Model (Super Regulator): Consolidate the supervision of banking, insurance, and securities industries under a single institution. The advantage is that the monitoring of the entire financial system won't become chaotic due to cross-industry operations, and supervision under multiple industries streamlines work. For large institutions, having only one compliance system reduces compliance costs. However, under multi-industry supervision, there are doubts about finding talent proficient in multiple industries, and coordination of supervisory work may not be adequate.
Examples: Japan, South Korea, Singapore, Norway, Denmark, Germany, and banking and insurance in Mainland China.
(c) Twin Peaks Model: The "Twin Peaks" model was first adopted in Australia in 1998, with two separate regulatory bodies. The first is responsible for the overall financial stability of individual financial institutions (microprudential supervision) and overall financial stability (macroprudential supervision). The other institution focuses on protecting consumers and investors (market conduct supervision).
This "Twin Peaks" model has both advantages and disadvantages. While multiple regulations can reduce the possibility of systemic inconsistencies and regulatory arbitrage, dual regulation simultaneously increases the compliance burden, leading to higher regulatory costs for both public and private sectors.
Examples: Australia, New Zealand, UK, Netherlands, Belgium.
5. Conclusion
5.1 There is no universally best system; each region must find the most suitable framework for its circumstances.
5.2 We recommend improving the current "super regulator" model by establishing a comprehensive body for regulation and development, similar to the Hong Kong Monetary Authority's dual role in banking development and regulation, balancing both aspects and avoiding extreme regulatory approaches.
5.3 The HKMA's initiatives like the FPS system, RMB business, and bank swaps exemplify effective development without compromising regulation.
5.4 In contrast, the SFC's initiatives, such as regulatory sandboxes and mutual recognition of funds, do not directly benefit the securities industry.
5.5 We urge the government to consider our suggestions to enhance the development and regulatory framework for the securities, futures, asset management, and virtual asset industries.
For any inquiries regarding this letter, please feel free to contact me at or via email at , or reach out to Mr. Wong Hoi-lok Ivan, Director of the Industry Department, at or email
Sincerely,
Mofiz Chan
Chairman
Hong Kong Securities and Futures Professionals Association
Government Headquarters, 24th Floor
Financial Services and the Treasury Bureau
Government of the Hong Kong Special Administrative Region of the People's Republic of China
To: The Government of the Hong Kong Special Administrative Region of the People's Republic of China
Financial Services and the Treasury Bureau
Mr. Christopher Hui, Secretary
Mr. Joseph Chan, Under Secretary
Proposal for Enhancing the Development and Regulatory Framework of the Securities, Futures, Asset Management, and Virtual Asset Industries
Dear Secretary Christopher Hui and Under Secretary Joseph Chan,
1. Introduction
1.1 Recent developments such as (1) Indonesia surpassing Hong Kong in IPOs to become the fourth-largest globally; (2) the market value of a single American company, Apple, equaling two-thirds of Hong Kong's total market value (as of July 4, 2023); and (3) the trading volume of Tesla in the U.S. being 2.86 times that of Hong Kong's entire market highlight significant challenges.
1.2 The Hong Kong securities, futures, and asset management industries (hereinafter referred to as "the industries") have been under regulatory and structural review since the 2008 "subprime crisis" triggered the "Lehman Brothers mini-bond incident." Then-Financial Secretary John Tsang directed the Hong Kong Monetary Authority and the Securities and Futures Commission (SFC) to conduct internal reviews and propose strengthening measures. However, these actions primarily focused on banking and brokerage sales practices and led to a series of suitability requirements, rather than a comprehensive review of developmental and regulatory mechanisms.
1.3 Looking back over decades, regulatory laws for the securities and futures industries were established a year after the 1973 stock market crash. Two non-permanent committees were created to oversee securities and commodities trading. Following another crash in 1987, a committee led by chartered accountant Mr. Ian Hay Davison reviewed the organizational, regulatory, and operational aspects of the relevant government departments, leading to the "Davison Report." The report, published in May 1988, recommended creating a new market regulatory body outside the civil service structure, which eventually became today's SFC.
1.4 Post the 1998 Asian financial crisis, a review led to the consolidation of previous securities and futures market regulations, culminating in the Securities and Futures Ordinance effective April 1, 2003.
1.5 Following the 2002 "penny stocks incident," then-Financial Secretary Antony Leung commissioned a review by Mr. Robert Kotewall and Mr. Gordon Kwong. The resulting "Penny Stocks Incident Report" expressed doubts about the existing three-tier organizational structure's effectiveness in fulfilling its functions.
1.6 The SFC was established to protect small investors' interests, maintain and promote fairness, efficiency, competitiveness, transparency, and order in the securities and futures industries. It was not tasked with development functions, focusing solely on regulation.
1.7 The Financial Development Council, not a government department but a limited company established by the government, lacks actual authority.
1.8 There is no authoritative body in Hong Kong specifically dedicated to the development of the industries, including InvestHK and the Hong Kong Trade Development Council.
2. 2022 Profit Data of Hong Kong Securities Dealers
According to the SFC's “Financial review of the securities industry” for the year ending December 31, 2022, the net profit of Hong Kong securities dealers was HKD 22.866 billion, a 65% decrease from the previous year.
3. Current Development Authority for the Hong Kong Securities Industry
3.1 Responsibilities of the Financial Secretary
The government traditionally adheres to a “positive non-interventionism” policy, rarely directly guiding industry development. According to the "Responsibilities of the Financial Secretary and the Secretary for Financial Services and the Treasury" announced by the Chief Executive on June 27, 2003:
(2) The Financial Secretary is responsible for:
(a) Monetary System;
(b) Exchange Fund;
(c) Public Finance;
(d) Financial System; and
(e) Hong Kong's status as an international financial center.
(4) Regarding public finance, the financial system, and Hong Kong's status as an international financial center, the Financial Secretary sets macro policy objectives, while the Secretary for Financial Services and the Treasury formulates specific policies to achieve these goals and implements them through regulatory bodies and other organizations.
In February 2003, the Financial Regulatory Council was established, chaired by the Secretary, with the aim of enhancing the efficiency and effectiveness of regulation and supervision of financial institutions in Hong Kong, promoting the development of financial markets, and helping to maintain market stability. Its members include representatives from the Hong Kong Monetary Authority, the Securities and Futures Commission, the Insurance Authority (“IA”), the Mandatory Provident Fund Schemes Authority, the Accounting and Financial Reporting Council, and the Financial Services and the Treasury Bureau. However, there have been no public meeting records available to date.
3.2 Responsibilities of the Secretary for Financial Services and the Treasury
As outlined in the "Responsibilities of the Financial Secretary and the Secretary for Financial Services and the Treasury":
(5) Therefore, the primary responsibility of the Secretary for Financial Services and the Treasury is to ensure the effective implementation of the specific policies mentioned in paragraph 4. In fulfilling these duties, he should liaise with and seek advice from relevant internal and external parties. As the custodian of these policy areas, the Secretary should keep the Financial Secretary informed of any matters that may require action under the statutory or other powers entrusted to the Financial Secretary. When exercising these powers, the Financial Secretary may, when deemed appropriate, seek the advice of the Secretary for Financial Services and the Treasury.
The responsibilities of the Secretary and the Director, as outlined in sections 2.1 and 2.2, primarily focus on "formulating specific policies" as mentioned in paragraph 4. However, there is no explicit mention of responsibilities related to leadership and development within the industry.
In February 2003, the Financial Market Stability Committee was established, chaired by the Secretary, with the goal of emphasizing the importance of stabilizing Hong Kong's financial markets. Members include representatives from the Hong Kong Monetary Authority, the Securities and Futures Commission, and the Insurance Authority. However, there have been no public meeting records available thus far.
The Financial Services and the Treasury Bureau's Financial Services Branch is the department that oversees the securities industry.
The Financial Services Branch of the Financial Services and the Treasury Bureau governs the securities industry, with a budget of HKD 760.7 million for 2023/24 and a staffing establishment of 109 positions as of March 31, 2023. This allocation is mismatched with the scale of the Hong Kong securities industry.
The funding and staffing allocation is simply not commensurate with the scale of Hong Kong's securities industry.
3.3 Responsibilities of the SFC
Founded to protect small investors and promote fairness, efficiency, competitiveness, transparency, and order in the securities and futures industries, the SFC lacks developmental functions, focusing solely on regulation. The SFC has not requested funding from the Legislative Council since 1993-94, funding itself through market levies.
For 2023-24, the budgeted revenue is HKD 1.90817 billion, with operating expenses of HKD 2.47448 billion. The SFC proposes adding four new positions, totaling 1,022 staff.
3.4 Responsibilities of the Hong Kong Exchanges and Clearing Limited (HKEX)
As a listed company in Hong Kong, HKEX aims to develop its business but is not a driver for industry development.
3.5 Responsibilities of InvestHK
InvestHK, a department under the Commerce and Economic Development Bureau, promotes foreign direct investment and assists Mainland China, Taiwan, and overseas enterprises in establishing and expanding in Hong Kong, fostering long-term partnerships.
InvestHK's fields include:
1. Business and Professional Services;
2. Creative Industries;
3. Financial Technology;
4. Innovation and Technology;
5. Transportation, Infrastructure, and Advanced Manufacturing;
6. Consumer Products;
7. Information and Communications Technology;
8. Tourism and Hospitality;
9. Financial Services.
With a 2023/24 budget of HKD 278.2 million and 40 positions as of March 31, 2023, the scope of its work raises concerns about meeting industry needs effectively, given its affiliation with the Commerce and Economic Development Bureau rather than the Financial Services and the Treasury Bureau and the breadth of its nine fields, including financial services.
However, (1) being under the Commerce and Economic Development Bureau instead of the Financial Services and the Treasury Bureau, whether it can effectively implement the industry's timely needs becomes a problem. (2) There are nine different domains, and "financial services" includes banking, foreign exchange, insurance, securities, futures, virtual assets, asset management, and so on.
To put it bluntly, with only 40 positions tasked with overseeing 9 different business domains, how can they adequately cater to the needs of the securities industry? The funding and staffing allocation is simply not commensurate with the scale of Hong Kong's securities industry.
3.6 Responsibilities of the Hong Kong Trade Development Council (HKTDC)
The Trade Development Council (TDC) falls under the Commerce and Economic Development Bureau, and is responsible for promoting, assisting and developing Hong Kong's trade. Its departments include:
(1) Exhibition and Digital Business
(2) Communications and Promotion
(3) Research
(4) Commodity Trade and Innovation
(5) Services Promotion
The last two departments are involved in financial services.
The budget allocation for the 2023-24 fiscal year is HK$640.2 million, but there are no data on the number of staff.
However, based on general observation, the Trade Development Council is not heavily involved in promoting the securities industry.
3.7 In summary, based on the above 6 points, the Hong Kong securities industry and its market capitalization do not have a dedicated department specifically managing the development of the securities industry. The budget for the Financial Services Branch under the Financial Services and the Treasury Bureau is HK$253.6 million (out of a total budget of HK$760 million for the bureau, with 3 deputy secretaries, of which the securities industry is one-third, i.e. HK$253.6 million). Adding the HK$30 million budget for the Investment Promotion Agency (out of a total budget of HK$278.2 million for 9 business areas), the total budget comes to HK$283.6 million. This is only about 1% compared to the HK$22.866 billion net profit of Hong Kong securities dealers in 2022. If compared to 2021, it is only 0.4%. The involvement in terms of manpower and budget is shockingly disproportionate!
3.8 However, the SFC, a regulatory body, has expenditures of HKD 2.47448 billion and a staffing total of 1,022, ten times that of the aforementioned departments.
4. Advantages and Disadvantages of the Three Major Global Financial Regulatory Frameworks
4.1 Globally, regulatory systems aim to: (a) reduce systemic risk; (b) maintain safety and soundness; (c) protect investors' interests; and (d) ensure market fairness.
4.2 The three main regulatory systems are:
(a) Segregated Model: Hong Kong, along with many other places, adopts the sectoral regulatory model, which is the most common regulatory system globally. It is relatively simple and can save a lot of administrative costs, with independent regulators overseeing single industries and handled by experts. This system is often further strengthened with more cross-sector coordination after financial crises.
However, the advantage of this model is also its drawback. Since the regulatory bodies only focus on regulatory matters, they do not handle industry development. In order to demonstrate that their regulated sectors have no regulatory flaws, the regulators may gradually shift towards an overly stringent regulatory approach, without properly balancing the needs of industry development.
Examples: Mainland China, Portugal, Spain, Israel.
(b) Integrated Model (Super Regulator): Consolidate the supervision of banking, insurance, and securities industries under a single institution. The advantage is that the monitoring of the entire financial system won't become chaotic due to cross-industry operations, and supervision under multiple industries streamlines work. For large institutions, having only one compliance system reduces compliance costs. However, under multi-industry supervision, there are doubts about finding talent proficient in multiple industries, and coordination of supervisory work may not be adequate.
Examples: Japan, South Korea, Singapore, Norway, Denmark, Germany, and banking and insurance in Mainland China.
(c) Twin Peaks Model: The "Twin Peaks" model was first adopted in Australia in 1998, with two separate regulatory bodies. The first is responsible for the overall financial stability of individual financial institutions (microprudential supervision) and overall financial stability (macroprudential supervision). The other institution focuses on protecting consumers and investors (market conduct supervision).
This "Twin Peaks" model has both advantages and disadvantages. While multiple regulations can reduce the possibility of systemic inconsistencies and regulatory arbitrage, dual regulation simultaneously increases the compliance burden, leading to higher regulatory costs for both public and private sectors.
Examples: Australia, New Zealand, UK, Netherlands, Belgium.
5. Conclusion
5.1 There is no universally best system; each region must find the most suitable framework for its circumstances.
5.2 We recommend improving the current "super regulator" model by establishing a comprehensive body for regulation and development, similar to the Hong Kong Monetary Authority's dual role in banking development and regulation, balancing both aspects and avoiding extreme regulatory approaches.
5.3 The HKMA's initiatives like the FPS system, RMB business, and bank swaps exemplify effective development without compromising regulation.
5.4 In contrast, the SFC's initiatives, such as regulatory sandboxes and mutual recognition of funds, do not directly benefit the securities industry.
5.5 We urge the government to consider our suggestions to enhance the development and regulatory framework for the securities, futures, asset management, and virtual asset industries.
For any inquiries regarding this letter, please feel free to contact me at or via email at , or reach out to Mr. Wong Hoi-lok Ivan, Director of the Industry Department, at or email
Sincerely,
Mofiz Chan
Chairman
Hong Kong Securities and Futures Professionals Association