SFC concludes consultation on the position limit regime

Following the launch of two consultations on proposed revisions to its position limit regime (please see EventID #15414 and EventID 18459 in this context for more information), the Securities and Futures Commission of Hong Kong, SFC, has now published a consultation conclusion document in this context.
In this conclusion document, the SFC outlines the responses it has received to its second consultation (the responses to the first consultation are included in SAME document) and publishes the final amendments that will be made to the Securities and Futures (Contracts Limits and Reportable Positions) Rules and the Guidance Note on Position Limits and Large Open Position Reporting Requirements based on BOTH consultations.
To recall, in its second consultation, the Commission proposed
– to revise the position limits regime for stock options and futures contracts by expanding the current three-tier model based on liquidity and market capitalization of the underlying to a five-tier model.
– to remove mini stock index futures and options contracts from the position limit requirement.
– some changes as regards the expansion of the position limits to sub-fund to
– clarify that ALL funds regardless of the legal form will be subject to the new requirement;
– require all fund managers to observe position limits and report on positions at individual fund level; and
– provide that trustees are in compliance with the new requirements so long as they have adequate policies and procedures in place to ensure that the fund manager is compliant with the position limits and reporting requirements.
Based on the feedback received, the SFC has decided to proceed as proposed and implement the corresponding changes. However, to improve clarity for market participants, the Commission has made minor changes to the Guidance Note. Additionally, so the regulator, it will issue further guidance for market participants in the future if such is needed.
The final changes, INCLUDING those from the first consultation, are outlined in Appendices A, A1, A2, and B.