Investment Managers need to ensure they have in place appropriate systems and procedures to ensure they meet the Hong Kong Short Selling Reporting obligations of the funds that they manage.
Yesterday, the Financial Conduct Authority (FCA) fined a Hong Kong hedge fund just over £870,000 for failing to disclosure its net short position in Premier Oil Plc. This is the first time the FCA has taken enforcement action for a breach of the SSR.
The big month of liquidity finally arrived where we saw a number of liquidity developments come to fruition at the end of the month, including: ESMA’s new guidelines on liquidity…
Last week we took a brief look at the liquidity risk management regime in Hong Kong. This week, moving slightly southwest, and staying in the same continent, we review the liquidity risk requirements in Singapore. In 2018, the same year Hong Kong made amendments to its Fund Manager Code of Conduct, the Monetary Authority of Singapore (MAS) issued new Guidelines on Liquidity Risk Management Practices for Fund Management Companies (Guidelines).
Although liquidity risk management practices vary in different jurisdictions, in most cases, asset managers are required to monitor the liquidity of the fund on a frequent basis. Whilst many aspects of the regulations are broadly similar, differences can be seen from what is considered “liquid”, and around methodology to liquidity buckets, stress testing and reporting requirements. In Europe for example, neither UCITS nor AIFMD specify a specific methodology for calculating liquidity. This is in contrast to the US SEC Liquidity Risk Management Framework requirements which set out a specific methodology to be followed, although that methodology is not without its shortcomings.
This month’s regulatory round-up pulls together some interesting regulatory developments we have tracked throughout June. The past month brought a number of important developments, particularly on the EU Money Market Fund Regulation, with ESMA publishing updated reporting instructions, and translations to the MMF guidelines.