Derivatives 2024 – Hong Kong Chapter

1. Documentation and Formalities

1.1 Please provide an overview of the documentation (or framework of documentation) on which derivatives transactions are typically entered into in your jurisdiction. Please note whether there are variances in the documentation for certain types of derivatives transactions or counterparties; for example, differences between over-the-counter ("OTC") and exchange-traded derivatives ("ETD") or for particular asset classes.

In Hong Kong, derivatives transactions are typically documented using the framework of documentation published by the International Swaps and Derivatives Association ("ISDA").

OTC derivatives are customised contracts entered directly between two counterparties, and their documentation would typically include ISDA Master Agreements (1992 or 2002 versions), Credit Support Annex or Credit Support Deed where credit support is involved, and Confirmations that outline the commercial and other specific terms of the transactions. On the other hand, ETDs are standardised contracts traded on an exchange, and their documentation is usually based on the standard forms and following the rules and regulations of the appropriate exchanges, which ensures a more uniform approach to these ETD transactions.

Additionally, there may be variations in the documentation for particular asset classes, such as interest rate derivatives, credit derivatives, or equity derivatives. These variations would be reflected in the product-specific definitions and Confirmations that supplement the ISDA Master Agreements to cater to the unique features of each asset class.

ISDA's published definitions for the key asset classes (namely interest rates, foreign exchange ("FX"), equities, credit and commodities) include the: 2021 ISDA Interest Rate Derivatives Definitions, refining the previous 2006 ISDA Definitions; ISDA FX and Currency Option Definitions, applicable to FX and currency option transactions; 2002 ISDA Equity Derivatives Definitions for equity derivatives transactions, such as equity swaps, options, and forwards; 2014 ISDA Credit Derivatives Definitions for credit derivatives transactions, such as credit default swaps and credit-linked notes; and ISDA Commodity Definitions, covering commodity derivatives transactions, such as commodity swaps, options, forwards, and futures.

Furthermore, on 28 February 2022, ISDA published the 2022 ISDA Securities Financing Transactions ("SFT") Definitions and the SFT Schedule Provisions, allowing derivatives and SFT transactions that include derivatives, repos and stock loans to be documented under a single ISDA Master Agreement and enabling such derivatives, repos and stock loans to be governed by a single close-out netting arrangement under the ISDA Master Agreement.

This chapter focuses on OTC derivatives unless otherwise expressly stated.

1.2 Are there any particular documentary or execution requirements in your jurisdiction? For example, requirements as to notaries, number of signatories, or corporate authorisations.

In Hong Kong, there are no derivative-specific documentary or execution requirements under the law, as long as they comply with the company's constitutional documents and are executed within its corporate powers. Corporate authorisation documents, including board resolutions and, where applicable, shareholder resolutions and directors' certificates, are typically required. However, certain transactions may require additional terms depending on market practices. For instance, banks often apply their own standard terms to FX and equity derivatives transactions, which may dictate particular documentary or execution requirements.

1.3 Which governing law is most often specified in ISDA documentation in your jurisdiction? Will the courts in your jurisdiction give effect to any choice of foreign law in the parties' derivatives documentation? If the parties do not specify a choice of law in their derivatives contracts, what are the main principles in your jurisdiction that will determine the governing law of the contract?

In Hong Kong, English law is most often specified in ISDA documentation as the governing law of derivatives transactions. New York State law is also sometimes used. It is also not uncommon to see Hong Kong law-governed derivatives transactions with local banks and corporates, especially for derivatives products in the private banking sector and in retail structured products. The choice of a foreign law in derivatives documentation will be valid and given effect by Hong Kong courts, provided that such choice of law has been made in good faith, does not contravene Hong Kong public policy and is not intended to evade the provisions of another legal system with which the parties have a closer connection. Parties to a transaction often require legal opinions that the overall agreement will be enforceable under the proposed foreign law and the proposed foreign governing law would be given effect by Hong Kong courts.

If the parties do not specify a choice of law in their derivatives contracts, under Hong Kong conflicts of law rules, the governing law would be the law that has the "most real and substantial connection" with the transaction. However, in a cross-border trade, this determination may be difficult and could be a matter of debate between the parties, and a Hong Kong court would likely consider various factors. It is, however, very rare to find a properly documented derivatives contract where a choice of law is not specified.

2. Credit Support

2.1 What forms of credit support are typically provided for derivatives transactions in your jurisdiction? How is this typically documented? For example, under an ISDA Credit Support Annex or Credit Support Deed.

There are two main ways in which collateral is taken in Hong Kong: "security interest"; and "title transfer". The types of credit support provided in each transaction can vary, but may include cash, debt or equity securities, or guarantees or letters of credit from third-party financial institutions. Hong Kong parties to derivatives transactions often document credit support using either an ISDA Credit Support Annex or Credit Support Deed. For example, in the case of title transfer, the 1995 ISDA Credit Support Annex (Transfer – English law) or the 2016 ISDA Credit Support Annex for Variation Margin (VM) (Transfer – English law) is used, or where a security interest arrangement is contemplated, the ISDA 2018 Credit Support Deed for Initial Margin (IM) (Security Interest – English law) can be used. Other bespoke documentation can also be used.

2.2 Where transactions are collateralised, would this typically be by way of title transfer, by way of security, or a mixture of both methods?

Collateral in derivatives transactions can be taken in various ways depending on the nature of the transactions. For example, hedges for secured debt transactions are usually collateralised through security documents that secure the principal debt transaction, rather than through a separate Credit Support Annex or Deed. More information on this topic can be found in question 2.1.

2.3 What types of assets are acceptable in your jurisdiction as credit support for obligations under derivatives documentation?

There are two principal classes of collateral assets that are generally acceptable in Hong Kong as credit support for obligations under derivatives documentation: (i) cash and liquid equity; and (ii) fixed-income securities such as listed shares, US treasuries, corporate bonds and other readily marketable debt securities. Marketable debt securities are often issued or fully guaranteed by a sovereign, a relevant international organisation, a multilateral development bank or a public sector entity. The specific types of acceptable assets may depend on the nature of the transaction and the creditworthiness of the parties involved. In Hong Kong, where the counterparty borrower is a sizable PRC corporation and when it enters into hedges in connection with its underlying loan obligations, it is also common to see the use of standby letters of credit issued by a third-party bank as credit support.

2.4 Are there specific margining requirements in your jurisdiction to collateralise all or certain classes of derivatives transactions? For example, are there requirements as to the posting of initial margin or variation margin between counterparties?

Yes. In Hong Kong, the Hong Kong Monetary Authority ("HKMA") expects authorised institutions ("AIs") to adopt margins and other risk mitigation standards for non-centrally cleared OTC derivatives transactions. The collateral requirements for non-cleared OTC derivatives are outlined in Module CR-G-14 of the HKMA's Supervisory Policy Manual ("SPM"), titled "Non-Centrally Cleared OTC Derivative Transactions – Margin and other Risk Mitigation Standards" ("Margin Rules"). The Margin Rules include the requirements of posting initial margin ("IM") and variation margin ("VM") between counterparties in order to mitigate potential losses in events of default. Starting from 1 September 2022, Hong Kong has implemented the final phase of the IM requirements.

Covered products

The Margin Rules apply when AIs such as banks and approved money brokers, whether or not incorporated in Hong Kong, have entered into derivatives instruments on "covered products" with a "covered entity" (but if the AI is not locally incorporated, only in respect of non-cleared derivatives booked in its Hong Kong branch).

"Covered products" under the Margin Rules include: (i) all non-centrally cleared derivatives transactions, with the exception of repurchase agreements and securities lending transactions, which are not themselves derivatives but share some attributes with derivatives; (ii) indirectly cleared derivatives; (iii) physically settled FX forwards and FX swaps; (iv) the "FX transactions" embedded in cross-currency swaps associated with the exchange of principal; (v) physically settled commodity forwards; and (vi) non-centrally cleared single-stock options, equity basket options and equity index options (note: in light of the different approaches currently adopted by other jurisdictions on these non-centrally cleared equity options, the HKMA has extended the exemptions on these products until further notice).

There are also exemptions covering intragroup transactions between entities that are subject to consolidated supervision and meet certain requirements, and for transactions entered into by a securitisation special purpose vehicle ("SPV") for the sole purpose of hedging.

Covered entities

A "covered entity" is either a "financial counterparty" or a "significant non-financial counterparty".

A "financial counterparty" includes: (i) an AI, a corporation licensed by the Securities and Futures Commission ("SFC"), a Mandatory Provident Fund scheme, an authorised insurer, a licensed money lender, a collective investment scheme ("CIS"), a private equity fund, and an SPV or special purpose entity (but excludes an SPV that enters into uncleared derivatives transactions for the sole purpose of hedging); and (ii) a financial entity that belongs to a consolidated group for which the average aggregate notional amount ("AANA") of derivatives transactions exceeds HKD 15 billion.

A "significant non-financial counterparty" is any entity that: (i) is not a financial counterparty; and (ii) belongs to a consolidated group for which the AANA of derivatives transactions exceeds HKD 60 billion.

AANA threshold

AIs must exchange VM for all relevant non-centrally cleared derivatives entered into with a "covered entity" from 1 March 2017 to fully collateralise the current exposures of the derivatives transactions. Furthermore, as of 1 September 2022, AIs must exchange IM in respect of all relevant non-centrally cleared derivatives entered into with a "covered entity", where both the AI and "covered entity" have an AANA of these derivatives transactions exceeding HKD 60 billion in any one-year period (the "AANA threshold") (calculated from 1 September to 31 August).

IM threshold

Despite the AANA threshold, an AI may agree with a "covered entity" not to exchange IM if the amount due is equal to or lower than HKD 375 million (the "IM threshold"). The threshold is applied and shared at the level of the respective consolidated groups to which the AI or the covered entity belongs, and is based on all outstanding non-centrally cleared derivatives transactions between the two consolidated groups.

An investment fund managed by an investment advisor will be considered a separate entity for the purpose of applying the IM threshold as long as the fund is a distinct segregated pool of assets (from the assets of its investment advisor) and would be treated as such in insolvency or bankruptcy scenarios of either the fund or the investment advisor, and the fund is not collateralised, guaranteed or otherwise supported by the investment advisor or any other investment fund managed by the investment advisor.

There are also various requirements for safeguarding the IM collected. For example, it is preferable to hold the IM collected under custodian arrangements, ideally managed by third-party custodians; alternatively, sufficient asset segregation measures should be implemented, accompanied by legally valid documentation. Additionally, except limited exceptions, the re-hypothecation, re-pledging, or any form of reuse of the IM collected is prohibited under the terms of the relevant contracts, such as custodian agreements.

SFC regime

In parallel, the SFC had also proposed and consulted upon similar risk mitigation and margining requirements applicable to licensed corporations ("LCs") and their counterparties in non-centrally cleared derivatives transactions. The SFC issued the "Consultation Conclusions on the OTC derivatives regime for Hong Kong – Proposed margin requirements for non-centrally cleared OTC derivative transactions" in December 2019, setting out similar margin requirements, which are applicable to LCs with appropriate modifications and clarifications.

Starting from September 2020, a licensed person who enters into a non-centrally cleared OTC derivatives transaction should implement the risk mitigation and margin requirements set out in Parts I and III of Schedule 10 to the Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission ("Code of Conduct").

On 15 January 2024, the SFC announced its decision ^[i] to defer the effective date of its margin requirements for non-centrally cleared OTC single-stock options, equity basket options, and equity index options until 4 January 2026 (extended by two years from the original effective date of 4 January 2024).

The SFC's decision aligns the effective date of its margin requirements with the UK and EU timelines. The SFC explained that this is to prevent regulatory arbitrage, considering that licensed corporations' exposures to these non-centrally cleared equity options are currently insignificant (note: the SFC also indicated that Paragraph 7(e) of Part III of Schedule 10 to its Code of Conduct will be amended accordingly and gazetted in due course).

As regulatory requirements may be subject to change from time to time, it is recommended to refer to the latest information on the HKMA and SFC's websites.

2.5 Does your jurisdiction recognise the role of an agent or trustee to enter into relevant agreements or appropriate collateral/enforce security (as applicable)? Does your jurisdiction recognise trusts?

Yes. In Hong Kong, the role of an agent or trustee to enter into relevant agreements, or appropriate collateral, or to enforce security is recognised. Trusts are also recognised in Hong Kong. It is recommended that a trustee should only enter into agreements or take appropriate collateral/enforcement actions on behalf of a trust if they are duly authorised under a relevant trust deed. A trust deed may be governed by Hong Kong law, English law, New York law or other laws, and would typically follow the governing law of the relevant security documents.

2.6 What are the required formalities to create and/or perfect a valid security over an asset? Are there any regulatory or similar consents required with respect to the enforcement of security?

There are four main types of security interests in Hong Kong: charges; mortgages; pledges; and liens. If the security provider is a Hong Kong incorporated company or a registered non-Hong Kong company under Part 16 of the Companies Ordinance of Hong Kong (Cap. 622 of the Laws of Hong Kong), and the asset falls into a registrable category (covering any floating charge and fixed security over most, but not all, asset types), the security interest must be registered within one month of the relevant security document's creation against the security provider at the Companies Registry of Hong Kong.

Aside from the above, no other regulatory consents are required for security enforcement in Hong Kong, provided that the collateral provider is not in insolvency proceedings. For example, a secured party can enforce an enforceable and properly perfected, first-ranking, Hong Kong law-governed, fixed security interest over shares located in Hong Kong through its out-of-court power of sale.

On the other hand, enforcing security after the collateral provider's insolvency may be subject to Hong Kong law restrictions. There are so-called "clawback periods" before a Hong Kong company's liquidation commencement date, during which transfers or dispositions may be clawed back or set aside upon challenges by a liquidator or other insolvency officials, on grounds such as unfair preference, undervalue transactions, and voidable floating charge.

In August 2021, Hong Kong implemented a statutory automatic stay regime, potentially imposing further restrictions on security enforcement during insolvency situations involving a Hong Kong AI as a counterparty in a derivatives contract. It is crucial to consider the implications of these automatic stay rules when handling security enforcement, particularly when affected entities involve Hong Kong AIs, their holding companies, and their other group companies that are not classified as Hong Kong AIs. For a more detailed discussion on this topic, please refer to question 4.2 below.

3. Regulatory Issues

3.1 Please provide an overview of the key derivatives regulation(s) applicable in your jurisdiction and the regulatory authorities with principal oversight.

Overview

The Securities and Futures Ordinance (Cap. 571 of the Laws of Hong Kong) ("SFO") is the primary legislation, which sets out, among other things:

1. the licensing requirements for dealers in Hong Kong and the framework for mandatory clearing, reporting, record-keeping and trading requirements in Hong Kong;
2. the authorisation requirements for advertisement, invitation, disclosure or offering documents in respect of the offering of structured products or derivatives products to the general public in Hong Kong; and
3. civil and criminal liabilities in respect of market misconducts, including but not limited to insider dealing, false trading, price rigging, stock market manipulation, and disclosure of false and misleading information-inducing transactions.

Derivatives transactions that reference shares of a Hong Kong Stock Exchange listed company or other listed securities are also subject to the Rules Governing the Listing of Securities on the Stock Exchange of Hong Kong Limited.

Key derivatives regulations

The regulatory framework in Hong Kong consists of the SFO and its relevant pieces of subsidiary legislation, as well as the guidelines and circulars issued by the SFC and HKMA for the implementation and operation of these rules. The purpose of these derivatives regulations is to increase transparency, reduce systemic risk, and ensure a fair and orderly OTC derivatives market in Hong Kong.

Key derivatives regulations in Hong Kong include:

• The Securities and Futures (OTC Derivative Transactions – Reporting and Record Keeping Obligations) Rules 2016 (Cap. 571AL of the Laws of Hong Kong), setting out a mandatory reporting and record-keeping regime for certain prescribed persons engaging in non-cleared OTC derivatives activities.
• The Securities and Futures (OTC Derivative Transactions – Clearing and Record Keeping Obligations and Designation of Central Counterparties) Rules (Cap. 571AN of the Laws of Hong Kong), outlining a mandatory clearing regime, with effect from 1 July 2017, for example, to specify the applicable clearing threshold for an AI, approved money broker, or LC to follow, and what OTC derivatives transactions are subject to the clearing obligation, with any applicable exemptions.
• On 3 March 2023, the SFC and HKMA jointly published detailed FAQs on the Implementation and Operation of the Mandatory Clearing Regime for in-scope OTC derivatives. These FAQs are intended to help market participants better understand their obligations and responsibilities under the OTC derivatives regime.
• Additionally, certain classes of non-cleared derivatives are subject to mandatory margining requirements. These requirements apply to AIs that are either locally incorporated or have non-cleared derivatives booked in its Hong Kong branch. The specific margining requirements depend on the notional amount of the derivatives transaction. For further information in this respect, please refer to question 2.4 above.
• For the implementation of the Basel III final reform package, the Banking (Capital) Rules (Cap. 155L of the Laws of Hong Kong) (the "Rules") and related amendments form the key pieces of legislation. Specifically, by the operation of the Banking (Capital) (Amendment) Rules 2023, the revised market risk and credit valuation adjustment ("CVA") risk capital frameworks will be set out in Parts 8 and 8A of the Rules, respectively. They will come into effect on a day to be appointed by the HKMA (intended to be 1 January 2025). ^[ii]
• In relation to the Rules, on 15 March 2024, the HKMA issued new SPM modules – MR-1: Market Risk Capital Charge and MR-2: CVA Risk Capital Charge – as statutory guidance. Both new SPM modules are designed to provide additional technical details (in addition to the Rules) and to cover all the related requirements. They set out the minimum standards that all locally incorporated AIs are expected to adopt for the calculation of their market risk and CVA risk capital charges.

The regulatory framework governing Hong Kong's OTC derivatives market has undergone multiple amendments since its inception in 2016. These amendments reflect the regulators' ongoing efforts to modernise the regulatory regime to align it with international standards. It is anticipated that further revisions will be made in the future to ensure that the regulatory framework remains up to date and aligned with international financial regulations.

Regulatory authorities

The SFC and HKMA are the two primary financial services regulators and jointly oversee the OTC derivatives regime in Hong Kong.

The SFC administers and supervises securities and futures markets in Hong Kong, including OTC derivatives and SFC-licensed or registered persons. The SFC is responsible for the public consultation, formulation and enforcement of derivatives regulations, and issues and updates guidelines and codes of conduct for licensed or registered persons.

The HKMA supervises AIs such as banks and approved money brokers in relation to their OTC derivatives activities, and issues relevant rules through supervisory manuals and circulars. These include Module CR-G-14 as mentioned in question 2.4 in relation to margining requirements, the new SPM modules on Market Risk/CVA Risk Capital Charges as mentioned in question 3.1, a circular on phase 2 reporting requirements for OTC derivatives, and guidelines on exercising disciplinary power to order a pecuniary penalty under the SFO in respect of OTC derivatives.

3.2 Are there any regulatory changes anticipated, or incoming, in your jurisdiction that are likely to have an impact on entry into derivatives transactions and/or counterparties to derivatives transactions? If so, what are these key changes and their timeline for implementation?

As mentioned in question 2.4, Module CR-G-14 was updated on 11 September 2020. It is yet to be seen whether further amendments will be made in respect of margin requirements. On 28 January 2022, the HKMA and SFC jointly issued circulars to banks and SFC-licensed intermediaries with new guidelines targeting Virtual Asset-related ("VA") products including VA-related derivatives products, and there may be further updates to these guidelines as the VA market continues to develop in Hong Kong. For the latest updates on the final phase of LIBOR transition for OTC derivatives transactions, please refer to question 8.2 below.

On 20 March 2023, the Securities and Futures (OTC Derivative Transactions – Reporting and Record Keeping Obligations) (Amendment) Rules 2023 (L.N. 61 of 2023) were gazetted, providing for certain amendments to the Securities and Futures (OTC Derivative Transactions Reporting and Record Keeping Obligations) Rules. These amendments provide for an exemption from the OTC derivatives reporting rules under Chapter 571AL for a new Type 13 intermediary (see further details in question 3.3) that is a counterparty to specified OTC derivatives transactions in its capacity as a trustee of a relevant CIS. The amendments also provide for records that are required to be kept by such persons by virtue of it being a counterparty to a specified OTC derivatives transaction in its capacity as a trustee of a relevant CIS. These amendments will become effective on 2 October 2024.

Implementation timeline for the Basel III final reform package

On 10 November 2023, the HKMA issued a letter to the Hong Kong Association of Banks (the "Letter"), ^[iii] updating the timetable for the implementation of the Basel III final reform package after further consultation on the draft rules.

In accordance with the Letter:

• all standards in the package (on credit risk, operational risk, market risk, CVA risk and the output floor) will take effect on 1 January 2025; and
• the reporting-only requirement for the new standards on market risk and CVA risk will commence on 1 July 2024, as planned.

The HKMA will consider whether further refinements are necessary before finalising them for submission to the Legislative Council for negative vetting. During the reporting-only period, local AIs would still calculate their regulatory market and CVA risk capital charges based on the existing Rules.

Hong Kong's reporting-only timeline is slightly ahead of the UK and EU, while the full implementation of the new standards is aligned with the new timeline in the UK and EU, which is expected to be 1 January 2025, and closer to the revised implementation date consulted in the US, which is 1 July 2025.

3.3 Are there any further practical or regulatory requirements for counterparties wishing to enter into derivatives transactions in your jurisdiction? For example, obtaining and/or maintaining certain licences, consents or authorisations (governmental, regulatory, shareholder or otherwise) or the delegating of certain regulatory responsibilities to an entity with broader regulatory permissions.

The SFO prohibits a person from carrying out a regulated activity unless the person is an LC or an AI that is duly authorised and registered under the SFC regime. Dealing in and/or advising on derivatives may constitute regulated activities of "dealing in securities" (Type 1), "dealing in futures contracts" (Type 2), "advising on securities" (Type 4), "advising on futures contracts" (Type 5), and/or "securities margin financing" (Type 8) as stipulated in the SFO, unless an exemption or exception can be relied upon. An example of a commonly used exemption is where an investment manager who has a Type 9 (asset management) licence advises on a futures contract covered under Type 5, in which case the manager will not be required to apply for a Type 5 licence as long as it is proved to be wholly incidental to the manager's asset management business.

In June 2020, the SFC submitted proposed amendments to the OTC derivatives licensing regime as part of the Securities and Futures and Companies Legislation (Amendment) Bill 2021 to the Legislative Council, introducing the SFC-regulated activities of "dealing in OTC derivative products or advising on OTC derivative products" (RA 11) and "providing client clearing services for OTC derivative transactions" (RA 12). The date on which the amended regime will come into effect has not yet been fixed. For ETDs, the rules and procedures of the Stock Exchange of Hong Kong Limited, Hong Kong Futures Exchange Limited, the SEHK Options Clearing House Limited and HKFE Clearing Corporation Limited impose various requirements and obligations on their respective participants.

Additionally, in 2019, the SFC proposed a new regulatory framework on Type 13 regulated activity (RA 13), to supervise trustees and custodians of funds in Hong Kong. The regulatory regime focuses on how trustees and custodians safeguard scheme assets and oversee scheme operations. In 2022, after consultation, the SFC refined the definition of RA 13 to "providing depositary services for a relevant CIS (i.e., collective investment scheme)". The regulatory framework focuses on two core functions of a depositary: custody and safekeeping of scheme property; and oversight of the operation of the relevant CIS to ensure compliance with its constitutive documents. The implementation date for the new regime is also yet to be fixed.

3.4 Does your jurisdiction provide any exemptions from regulatory requirements and/or for special treatment for certain types of counterparties (such as pension funds or public bodies)?

Pension funds in Hong Kong are schemes that are registered under either the Mandatory Provident Fund Schemes Ordinance (Cap. 485 of the Laws of Hong Kong) or the Occupational Retirement Schemes Ordinance (Cap. 426 of the Laws of Hong Kong). There are certain requirements to be met by such schemes before they can enter into derivatives transactions.

According to the Code on Unit Trusts and Mutual Funds issued by the SFC, retail unit trust funds may only use derivatives for the purposes of and to such extent prescribed in its investment objectives, policies and restrictions. Generally speaking, derivatives that are used for hedging purposes are subject to less restrictions than those for speculative purposes. For example, a securitisation SPV that entered into uncleared OTC derivatives transactions with a financial institution is exempt from the margining requirements as discussed in question 2.4, if and to the extent that the SPV entered into such OTC derivatives transactions for the sole purpose of hedging.

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Originally published by ICLG

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