FIA has responded to the Hong Kong SFC's Consultation Paper on Proposed Risk Management Guidelines for Licensed Persons Dealing in Futures Contracts.
FIA supports the overall goal of the risk management guidelines and welcomes a number of the proposals. FIA also raises concerns around some of the proposals, such as the requirement to designate a risk officer or manager for specific risks, the need to maintain an approved list of tradeable commodity products, the imposition of limits on concessionary margin, the requirement to appoint a back-up executing or clearing agent and the waiver of margin calls based on set thresholds.
FIA suggests that a one-size-fits-all approach should be avoided and instead advocates for greater flexibility to be given to futures brokers as long as the necessary risk controls and reporting requirements are in place.
Read the full response.
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