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 proposals to regulate such powerful greenhouse gases with high global warming potential and suggests that the Government takes into account the operational practicalities that businesses are faced with during the implementation. We propose that the Government defer the implementation of the ban on sale and supply, as well as on-product labeling requirements, to allow businesses more time to comply with minimal disruptions.

The Chamber supports global efforts to develop common standards for ESG reporting as they could provide a useful reference guide for investors and issuers. We venture to suggest a deferral of implementation of mandatory climate-related reporting standards to allow sufficient time for all market participants, especially smaller cap issuers, to comply. The proposed mandatory requirements should also consider such factors as practicability and proportionality to avoid listing rule violations.