Submissions and Reports

The Chambers continues to express support for the Government’s efforts in developing a robust market for VA development in Hong Kong, thereby recommending that the development of the proposed licensing regime for over-the-counter VA trading services strikes a balance between facilitating the continued demand for VA trading opportunities amidst the rapidly evolving digital landscape, against the need to safeguard investor interests and preserve market integrity.
In its response, the Chamber also puts forward suggestions on the execution of the legislative proposals, in such aspects as the scope of services which would be permitted under the new licensing regime as well as the proposed supervisory scope.

The Chamber welcomes the HKEX’s proposals to enhance the GEM Listing regime in light of the recent significant decline of listings. We nevertheless suggest that greater strides should be taken to attract GEM’s main intended beneficiaries – growth and small and medium sized companies (SMEs), who are crucial contributors to Hong Kong’s economy and prosperity as an international financial city – so as to facilitate the success of such reforms. Recommendations on how to achieve such objectives, comprising cost reduction and relaxing financial eligibility requirements for GEM listing, reducing the profit requirement for entry to the Main Board, as well as enhanced promotion and outreach, are also outlined in the response.

The Chamber is generally supportive of the Hong Kong Monetary Authority’s proposals to simplify the existing three-tier banking system – through merging Deposit-taking Companies with Restricted Licence Banks to form a new second-tier - and recognize the benefits of such reforms as enhancing the industry’s role in strengthening Hong Kong’s status as an international financial centre. At the same time, we suggest that consideration could be given to further consulting key industry stakeholders on the potential implications of such changes on the banking system, so as to achieve a balanced and sustainable implementation of the initiative.

The Chamber welcomes the SFC’s introduction of a new regulatory framework for licensed virtual asset trading platform (VATP) service operators as well as proposals to allow retail investors to access services delivered by the former, provided that there is balance between supporting the development and demands in virtual asset trading, and providing robust protection to investors and market integrity. At the same time, the Chamber notes that there exist differences in industry views on the necessity and sufficiency of certain proposed investor protection mechanisms.

The Chamber welcomes the Government’s initiative to update the Talent List to address Hong Kong’s acute talent shortage situation and sustain a competitive economy, and puts forward recommendations on the necessary high-skilled professions for inclusion in the same.

The Chamber welcomes the HKLRC’s proposals to introduce a bespoke law that deals with the proliferation of cyber-dependent crimes given the risks of such illegal acts on Hong Kong’s businesses. The Chamber has also called for a balanced approach in the design of the new law so that other than the objective of protecting public interest, consideration should also be given to upholding business’ legitimate needs.

The Chamber welcomes the notion of an e-HKD as a digital legal tender given the associated benefits that would go towards consolidating the city’s standing as an international financial centre. The Chamber has also put forward design and implementation recommendations on the development of such a Central Bank Digital Currency.

The Chamber notes that despite the recent interest in and use of Special Purpose Acquisition Companies (SPACs) as a listing vehicle, there have been growing concerns and regulatory scrutiny in early adopter jurisdictions such as the United States. Should SPACs be approved in Hong Kong, the Chamber recommends that such instruments be subject to the HKEX’s Listing Rules to the greatest extent possible.

The Chamber welcomes the HKEX’s proposals to enhance its existing framework on corporate governance and related listing rules. At the same time, we recommend that such changes be implemented on an incremental and flexible basis, with consideration given to their potential costs and benefits for businesses, particularly with regard to the impact on small and medium sized issuers.

The Chamber agrees with the HKEX that the existing listing requirements should be streamlined through the introduction of a common set of core shareholder protection standards (“Core Standards”) especially in respect of overseas issuers. The Chamber has also made a number of observations and recommendations on certain aspects of the Core Standards to facilitate issuer compliance, and enhance the city’s status as a place to list.