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Relevant Practitioners

To whom is the ECF applied to?

The ECF applies to PWM industry practitioners (Relevant Practitioners) engaged by PWM institutions in customer-facing roles making personalized or customized solicitations or recommendations to customers in the provision of securities dealing and advisory service and/or portfolio management service.

For the purpose of the ECF, PWM institutions refer to the following:

  • (a) Private banks or authorized institutions with dedicated unit(s) that maintain a personalized relationship with private banking customers, and provide personalized banking services, dealing, advisory and/or portfolio management services to these customers; and
  • (b) SFC-licensed corporations with dedicated units(s) that maintain a personalized relationship with private banking customers, and provide dealing, advisory, and/or asset / portfolio management services to clients who fall under the definition of private banking customers*.

* A “private banking customer” refers to a customer who maintains a personalized relationship with the PWM institution and receives personalized banking services, dealing, advisory or asset / portfolio management services from the PWM institution, and has:
a) at least USD3 million or its equivalent in any other currency in investable assets; or
b) at least USD1 million or its equivalent in any other currency in investable assets under the PWM institution’s management.

Investable assets comprise securities, deposits and certificates of deposits. The amount may be calculated on a relationship basis covering (i) individual accounts; (ii) joint accounts with associates; and (iii) personal investment companies wholly-owned by the individual or jointly owned with associates. Associate means the spouse or any child of that individual.