Participants conducting the RMB Readiness Test are advised to summarize in the checklist the conclusions of their review of readiness in those applicable areas set out in the checklist. Participants should also keep a copy of the completed checklist for record.
Participants are reminded to prudently assess their readiness and be satisfied that they have already prepared themselves properly before confirming their readiness to HKEx.
Brokers providing currency conversion service to their clients should ensure the relevant exchange rate and / or basis of fixing the exchange rate has been clearly disclosed to and agreed with the clients. Brokers should also clearly disclose to the client their role in the transaction (as agent or principal) and ensure compliance with the Code of Conduct's requirements relating to conflicts of interest and compliance.
Those brokers who fail to ensure their readiness should refrain from dealing in RMB securities to be listed on the SEHK or clearing transactions in such securities. They should put in place measures to prevent inadvertent trading of, or acceptance of client trading instructions on, listed RMB securities. For example:
- Notify all staff in writing that no client trading instructions on listed RMB securities should be accepted
- Explain to clients clearly that no services in listed RMB securities are offered by your firm currently upon clients' enquiries
- Closely monitor trading activities. If inadvertent transaction in listed RMB securities is identified, contact HKEx immediately to discuss any need for taking remedial action
Brokers conducting trading / clearing activities in RMB securities to be listed on the SEHK without having ensured their readiness for conducting such activities shall be liable to regulatory scrutiny of their conduct.
Jack's comment: The checklist provided by SFC, asking only a lot of general questions, is basically useless. But SFC would claim they have got their job done.
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