Following the circular issued by the Securities and Futures Commission (SFC) on 24 January 2024 to licensed corporations wishing to participate in the Cross-Boundary Wealth Management Connect Pilot Scheme in the Guangdong-Hong Kong-Macao Greater Bay Area (Cross-Boundary WMC) (see our previous article for a summary), the SFC issued a new circular introducing significant enhancements to the Cross-Boundary WMC on 13 November 2025 to improve client communication under the broader investor protection restrictions.
Pursuant to the new SFC circular, the key changes include:
- One-off Written Consent (valid for up to one year)
Southbound clients may now give a one-off written consent, valid for up to one year, allowing Hong Kong participating licensed corporations (Participating LCs) to proactively contact them (via telephone, video conferences or messaging) to introduce and explain eligible investment products information based on clients’ needs and selected product categories. However, travel to Mainland for active substantive sales activities remain prohibited.
This one-off arrangement eliminates a pre-existing key operational hurdle where Participating LCs could only respond to ad-hoc client requests, and enables sales representatives to deliver more tailored and prompt investment insights. The arrangement is reciprocal for Northbound clients with Mainland partner brokers in the same corporate group as the Participating LC (Partner Brokers). - Three-Party Dialogues
Upon client request, online/telephone/video three-party dialogues could be arranged during which the Hong Kong-based Participating LCs (for Southbound) or Mainland Partner Brokers (for Northbound) can directly introduce and explain investment product features and risks. This brings Participating LCs in line with the three-party call regime introduced for banks in June 2025 (see our previous article for a summary of the Hong Kong Monetary Authority’s guidance on the promotion and sales arrangement under the southbound Wealth Management Connect scheme on 12 June 2025).
Participating LCs and their Partner Brokers are reminded that their responsibilities must be clearly defined in cooperation agreements to ensure full compliance with relevant regulatory requirements. - Research Reports on Individual Products
With explicit client consent under the one-off arrangement (see above), Participating LCs may provide Southbound clients with research reports on specific eligible investment products prepared by their Mainland Partner Brokers (previously restricted to macro or sector reports). It is worth noting that Participating LCs remain responsible for due diligence in the selection and ongoing monitoring of their partner brokers, quality control of the research reports and to ensure compliance with the applicable requirements in the Code of Conduct for Persons Licensed by or Registered with the SFC. Reciprocal rules apply to the Northbound scheme where clients clearly indicate acceptance for Partner Brokers to provide them with such research reports.
Since the announcement of the Cross-Boundary WMC, enhancements have been continuously made to broaden eligible products, and to make distribution of such products easier. The most recent enhancements above allow Participating LCs and Partner Brokers to engage existing Cross-Boundary WMC clients more proactively and efficiently, while enhancing investors’ access to information and facilitate informed investment decision-making. For Hong Kong Participating LCs, the relaxation creates compelling Greater Bay Area growth opportunities through deeper investor reach and strengthened cross-border communication.
For further information, please contact:
Ming Chiu Li, Partner, Deacons
mingchiu.li@deacons.com
