PwC HK: PricewaterhouseCoopers Hong Kong - …...regulatory updates impacting Hong Kong financial...

Regulatory Hot Issues

www.pwchk.com

September 2018

The 2nd edition provides an update on regulatory

developments in trending topics, including

corporate governance, insurance regulatory trends,

Basel III and HKMA supervisory developments.

It can become difficult to keep track of regulatory updates when new regulations and guidelines

are issued on a piecemeal basis almost everyday.

“Regulatory Hot Issues” aims to provide you with a recap on some of the most pertinent areas

that are challenging financial institutions. This publication will be released periodically as a

reminder of key regulatory updates impacting the financial services industry.

The last six months witnessed diverse

regulatory updates impacting Hong

Kong financial services sector.

In this edition of Regulatory Hot

Issues, we have covered the following

key developments.

Corporate governance: Amongst

the top focus areas for the SFC in 2018

is corporate fraud, and it has reflected

in two key updates – corporate

governance regime for listed issuers

and their directors and IPO

sponsorship regime.

Basel III and HKMA Supervisory

Developments: The HKMA is

developing and consulting on new

requirements stemming from the

finalized Basel III framework. These

include the revised Phase 2 disclosure

templates issued by the HKMA,

updating the SPM module on

counterparty credit risk (CCR), and

updating supervisory policy manual

module on validating risk rating

systems under the internal ratings-

based (“IRB”) approach.

Insurance sector: With the

Insurance Authority (IA) taking over

the statutory functions of the Office of

the Commissioner of Insurance, there

have been a significant volume of

regulatory developments in the Hong

Kong insurance market in the last few

months, including – a consultation

document on the draft guideline on

enterprise risk management (ERM

Guideline) and key findings from

onsite inspection visits to insurance

brokers.

Anti-money Laundering and

Counter Terrorist Financing

(AML/CFT): Hong Kong brought

into effect an update to the AML/CFT

Ordinance to better align with

international standards and facilitate

the use of technology. This is partly in

preparation for the Financial Action

Task Force’s (FATF) on-site mutual

evaluation assessment of the

effectiveness of the AML/CFT regime

and the implementation of the FATF

standards in Hong Kong is scheduled

for later this year.

Asset and Wealth Management

(AWM) sector: The AWM sector

saw several regulatory developments.

One of the key update is that Open-

ended fund companies (OFCs) can

now be established in Hong Kong,

which provides the option for Hong

Kong-domiciled open-ended

investment funds to be structured in a

corporate form rather than as unit

trusts. In addition, the SFC enhanced

fund reporting requirements for SFC-

authorised funds. The SFC also

published its consultation conclusions

on Proposed Guidelines on Online

Distribution and Advisory Platforms.

One of the key development in the

sector will be revisions to the Fund

Manager Code of Conduct (the FMCC)

becoming effective on 17 November

2018 .

Technology: Technology has been a

key focus area for regulators in Hong

Kong with the HKMA particularly

working towards the seven Smart

Banking initiatives. Hong Kong could

issue the first virtual banking licenses

as early as this year or early next year

with the HKMA announcing on 31

August 2018 that it has received 30

applications for the first batch of

licences. Moreover according to the

HKMA’s Cybersecurity Resilience

Assessment Framework (C-RAF), all

authorized institutions (AI) that had

not participated in the phase 1 need to

submit their independent gap

assessment at the end of 2018 as part

of phase 2 while some AIs have now

been put in “phase 3” with a

submission deadline of end of 2019.

Executive Summary

Regulatory Updates Newsletter — September 2018 PwC · 2

One of the top focuses of the SFC in

2018 is corporate fraud, and this has

been reflected in two key updates in

relation to corporate governance

and sponsorship expectations

released recently.

Corporate governance regime

for listed issuers and their

directors

To promote good corporate

governance and the effectiveness of

boards, the Stock Exchange of Hong

Kong Limited released the conclusions

from its consultation on its Corporate

Governance Code, the related Listing

Rules and “Guidance for Boards and

Directors” in July 2018 (the “HKEx

Guidance”).

These new measures, which take effect

from 1 January 2019, include:

• Strengthening the transparency

and accountability of the board

and/or nomination committee on

the election of directors, including

Independent Non-Executive

Directors (“INEDs”);

• Improving the transparency of

INEDs’ relationships with issuers;

• Enhancing the criteria for assessing

the independence of potential

INED candidates;

• Promoting board diversity and

requiring the establishment of a

diversity policy; and

• Requiring greater dividend

policy transparency.

The HKEx Guidance provides advice

to boards and directors in respect of a

number of areas, including

• Directors’ duties and board

effectiveness;

• Roles, functions and governance

matters; and

• Risk management and internal

control matters.

Whilst the majority of the matters

referred to in the HKEx Guidance are

similar to existing rules and codes, it

does re-emphasise directors’

accountabilities. These should be top

of mind as directors reassess the

adequacy of their abilities,

individually and in aggregate, as well

as their time commitments to

discharge their responsibilities.

In particular, the HKEx Guidance

reiterates the board’s responsibility

for risk management and internal

control, shaping and developing risk

culture, and tone from the top.

Expectations and suggestions on

approaching these matters, including

the process for risk identification,

risk assessment and risk

management, have also been set out

in the HKEx Guidance.

Corporate Governance

IPO Sponsorship Regime

The current sponsor regulatory regime

was established in 2013. Since then,

the SFC have continued to focus on

this segment of the market and they

published the results of their most

recent thematic review in 2018. The

SFC had observations over a number

of key areas over the sponsorship

process, as shown in the diagram on

the next page. We have supplemented

certain areas highlighted in the SFC’s

thematic review report based on our

experiences.

Whilst the industry is seeking to

respond to the SFC’s findings, they

have cited challenges in recruiting and

retaining talent, the cost of

compliance and an expectation from

listing applicants that due diligence

can be completed within ever shorter

timelines. Firms are now placing a

heavier emphasis on how annual

assessments can be used to drive

greater insights on their sponsor

control framework.



Sponsor framework

Resources, controls and

systems

Governance and supervision

Deal Principal Deal Committee

Due Diligence Planning

Annual assessment

Record Keeping

Due Diligence Execution

Key Business

Stakeholders

Reliance on Third

Parties and ExpertsEscalation

Due diligence planning

A number of failures can be

attributed to insufficient procedures

during the planning phase. In

particular, how due diligence plans

and deal teams have been tailored in

light of the listing applicant’s

industry, business operations and

circumstances.

Governance and supervision

Oversight Committees and Deal

Principals are continuing to face

challenges in how they demonstrate

the extent of their involvement in the

due diligence planning and execution

processes, in particular where

changes to the initial plan are

required or how issues are resolved.

Involvement of third parties

and experts

Whilst sponsors are clear about their

responsibility for involving third

parties and experts, they have

difficulties assessing the third parties’

work, including determining whether

the scope is adequate and reviewing

the appropriateness of the

conclusions drawn.

Professional scepticism

Sponsors are aware of the need to

apply professional scepticism in

respect of internal and external

stakeholders. However, they face

challenges in demonstrating how

this regulatory expectation has been

applied in practice. In particular,

addressing issues identified and

highlighting potential “red flags” is

difficult, as considerable experience

and professional judgement may be

needed.

Record keeping

Whilst firms provide guidance on the

principles determining document

retention, they do not have a

systematic way of compiling or

storing deal files. Accordingly, deal

files do not always contain all

required information and conclusions

reached, and there is a reliance on

individuals being able to locate the

relevant information in e-mail

inboxes when the need arises.

Annual Assessment

Deficiencies noted by the regulators

call into question the effectiveness of

the annual assessments. The annual

assessments must be sufficient in

scope, encompassing both policies

and procedures, and the application

of the aforementioned in actual

listing applications. The expertise

and independence of the reviewer

must also be considered to ensure the

effectiveness of the assessment.


PwC · 4Regulatory Updates Newsletter — September 2018

Corporate Governance

The HKMA is developing and

consulting on new requirements

stemming from the finalized Basel III

framework. While the consultation on

new Large Exposure Rules took place

earlier this year, authorized

institutions (“AIs”) are currently

asked to comment on a consultative

paper setting out the new Standardized

Approach for Counterparty Credit Risk

(“SA-CCR”). Consultations may start

later this year or early next year on

other capital requirements that will

come into effect in 2022.

Apart from these consultations, the

HKMA issued amended

requirements and guidelines on

regulatory disclosure, counterparty

credit risk, and internal model

validation as follows:

Basel III and HKMA Supervisory Developments

New Pillar 3 disclosure

requirements

The Basel Committee has been

working on the enhancement of global

disclosure regulations (“Pillar 3”) for

several years, with Phase 1 and phase

2 becoming effective in March 2017

and August 2018 respectively. Earlier

this year, the Basel Committee issued

a consultative paper on a Phase 3

revision which may bring additional

and more detailed disclosure

requirements, particularly for IRB

users, going forward.

The revised Phase 2 disclosure

templates issued by the HKMA

contain amendments to the existing

risk weighted assets (“RWA”)

disclosure template alongside a new

overview on an AI’s key prudential

metrics, regulatory capital

instruments, and liquidity risk

management. The Phase 2 disclosure

templates are applicable to the first

interim disclosure in 2018 as well as

the quarterly disclosure at the same

date. Disclosure templates on Interest

Rate Risk in the Banking Book

(“IRRBB”) have also been newly

introduced and are applicable for the

first annual reporting period ending

on or after 30 June 2019, in line with

the timeline for implementing other

IRRBB requirements.

Updated supervisory policy manual

module on counterparty credit

risk (“CCR”) (SPM CR-G-13)

The HKMA updated the SPM module

on counterparty credit risk (CCR) to

account for changes in the

international CCR regulations. The

amendments include:

• Credit assessment and review for

central clearing party (“CCP”) and

clients that are involved in client

clearing services;

• Adoption of appropriate credit

valuation adjustment (“CVA”)

measurement systems;

• More guidance on CCR mitigation

practices; and

• Extended rules on independent

reviews and audits of the CCR

management system and process.

AIs should now review their CCR

management system and processes

and come up with an approach to

implement and maintain the newly

extended requirements – like CCP-

or CVA-related rules – into the

existing system and process which

may be challenging.

New Personal Lending Portfolio

(NPP)

In May 2018, the HKMA issued a

guideline setting the stage for AIs to

carve out a “New Personal Lending

Portfolio (NPP)” which shall be

subject to innovative technology-

based credit risk assessment and

management approaches. This is part

of HKMA’s ‘Banking made easy’

initiative which aims to establish a

new era of Smart Banking in Hong

Kong, in connection with the Virtual

Banking licenses, Open-API rules, and

other actions.

The NPP should be limited to a

maximum 10% of the AI’s capital base

and the individual loan amounts shall

be smaller than those of regular

personal loans. To grant these NPP

loans, AIs do not need to obtain an

income nor an address proof, in

contrast to traditional loans. While

data analytics and innovative

solutions shall replace existing credit

assessment and risk management

approaches for these exposures, the

HKMA requires AIs to maintain a high

level of consumer protection,

including transparency and avoidance

of over-indebtedness. AIs intending to

make use of this arrangement should

discuss their proposals with the

HKMA individually.

AIs may leverage this opportunity to

apply new technological approaches

and prove their appropriateness for

managing credit risk. However, the

HKMA will observe and review the

effectiveness and soundness of those

solutions and decide about adjustments

to the NPP scope going forward.



Updated supervisory policy manual module on validating risk rating

systems under the internal ratings-based (“IRB”) approach (CA-G-4)

The SPM module CA-G-4 on "Validating Risk Rating Systems under the IRB

Approach" sets out the HKMA approach and requirements with respect to the

validation of the internal rating systems of locally incorporated AIs, which

should take place at least annually in order for the IRB approach to qualify

being used to measure credit risk for capital adequacy purposes.

In May 2018, the HKMA updated the module with additional details, including

the following key changes to align with the updated Basel III standards on the

IRB approach:

• Update and alignment with the final Basel II standards on the IRB approach

and subsequent revisions, with specifications of validation requirements on

various key aspects of an internal rating system;

• Incorporation of guidance and best practices for the validation of

IRB systems;

• Consolidation of two existing documents, namely Minimum Requirements

for Internal Rating Systems under IRB Approach and Minimum

Requirements for Risk Quantification under IRB Approach, into the main

text of the revised module as a new Annex E. These requirements cover

rating system design, rating system operations and disclosure requirements.

The validation of the IRB systems should cover the following additional aspects:

• an evaluation of model risk, together with an evaluation of the

appropriateness of margins of conservatism to cope with model and data

imperfections;

• an evaluation of model use, such as whether there are limitations on input

data, how overrides are documented, how model users are trained and

feedback received from model users; and

• performance test and back-testing at both aggregate model level and more

granular grade or segment levels.

The independent validation unit(s) should define a plan, activities, and review

processes for the validation, and perform its own tests of all material aspects of

the models. This includes the model performance, quality of databases used,

and data cleaning, and the independent tests should also cover tests already

performed by the model developers.



Basel III and HKMA Supervisory Developments

On 27 April 2018, the IA issued a

summary of key findings they

observed during their onsite

inspections to various insurance

brokers, which included suggested

good practices. The key findings

include:

• Failure to comply with the

minimum requirements specified

under section 69(2) and 70(2) of

the Insurance Ordinance, with

respect to keeping of separate

client account, proper

documentation of the

acknowledgement from clients, and

lack of monitoring over the

timeline regarding delivery of long

term insurance policies to clients,

• Non-compliance with the Anti-

Money Laundering and Counter-

Terrorist Financing Ordinance

(Cap.615), including lack of

appropriate written AML/CFT

policies, lack of own risk

assessment, failure to keep records

of customers’ identification

documents, lack of documentation

on the screening mechanism of

politically exposed persons (“PEP”),

terrorists and sanction

designations in procedural

manuals and screening results of

individual customers, failure to

establish and maintain sufficient

procedures to ensure all staffs were

made aware of the identity of

Money Laundering Reporting

Officer and suspicious transaction

reporting procedures, and lack of

AML/CFT training, and

• Performance requirements as

defined under section 34E of the

Mandatory Provident Fund

Schemes Ordinance (Cap. 485).

The IA released a consultation

document regarding the draft

guideline on enterprise risk

management (“ERM Guideline”) in

May 2018, which is scheduled to be

effective in 2020. This ERM Guideline

sets out the supervisory objectives,

guidance and expectations of the IA in

assessing the overall competence of an

insurer’s enterprise risk management

framework and Own Risk and

Solvency Assessment. The IA has

proposed a three-tier group-wide

supervisory approach over enterprise

risk management to enhance the

effectiveness of its supervision of

insurance groups.

Separately, following the first

Quantitative Impact Study for the

development of the Risk-Based

Capital Regime, the IA has

developed the technical

specifications and templates for the

second Quantitative Impact Study

(“QIS 2”). The IA has issued two

circulars to invite authorized

insurers to participate in QIS 2, and

the deadline for submission of data

is 30 November 2018.

On 27 July 2018, Mr. Clement Cheung Wan-ching was

appointed as the CEO of the IA for a term of two years, starting

from 15 August 2018. Mr. Cheung was the Commissioner of

Insurance in Hong Kong from 2006 to 2009.

With the Insurance Authority (IA) taking over the statutory

functions of the Office of the Commissioner of Insurance,

there have been a significant volume of regulatory

developments in the Hong Kong insurance market in the

last few months. Key developments have been summarized

as follows:

Key findings from onsite inspection visits to insurance brokers

New Chief Executive Officer of the IA

Updates on the development of Risk-Based Capital Regime

Regulatory Hot Issues — Insurance


Revised Guideline on Anti-

Money Laundering and Counter-

Terrorist Financing (“GL3”)

GL3 came into effect on 1 March 2018.

It was amended to reflect the recent

enacted Anti-Money Laundering and

Counter-Terrorist Financing

(Financial Institutions) (Amendment)

Ordinance 2018. The key

amendments include:

• revising the threshold of

defining beneficial ownership

from “not less than 10%” to “more

than 25%”,

• introducing flexibility to measures

permitted to be taken for verifying

a customer’s identity,

• permitting financial institutions to

rely on foreign financial

institutions within the same

financial group as intermediaries

to carry out customer due diligence

measures, and

• changing the record-keeping

period from “six years” to “at least

five years”.

Circular on key findings of

AML/CFT onsite inspection visits

to authorized insu rers

The circular summarized the key

findings based on the onsite

inspections to more than 20

authorized insurers carrying on

long-term business in Hong Kong.

Key areas of improvement

identified include:

• Senior management oversight

over compliance review process,

rectification process, polices &

procedures and due diligence

measures for high risk customers,

• Compliance functions relating

to the regularity of report

submission to senior management

and accuracy and completeness of

information reported,

• Customer risk assessment,

• Collection and maintenance of

required information during

customer due diligence

process, including high quality of

identification documents,

• Screening of PEP, terrorist and

sanction designations at the time of

establishment of business

relationship or on an ongoing basis,

• Ongoing monitoring over

customer transactions and

activities, recording of data for high

risk customer and conducting

review of policyholders’

information upon trigger events,

• Documentation and timeliness of

suspicious transaction

reporting and mitigation of risk

in relation to tipping off by

staff, and

• Staff/agent training.

AML/CFT guidance from the IA

Anti-money Laundering and Counter Terrorist Financing (“AML/CFT”)

The Financial Action Task Force’s

(“FATF”) on-site mutual evaluation

assessment of the effectiveness of the

AML/CFT regime and the

implementation of the FATF

standards in Hong Kong is scheduled

for later this year.

In March 2018, Hong Kong brought

into effect an update AML/CFT

Ordinance to better align with

international standards and facilitate

the use of technology. While the

Government is still conducting the final

preparations for the FATF assessment,

the regulators are now in the process of

updating their AML/CFT Guidelines

and are consulting with the industry on

this matter.

Key highlights of the proposed

amendments, which are expected to

become effective on 1 November

2018, are:

• Expansion of the types of

Politically Exposed Persons

(“PEPs”) to include persons who

have been entrusted with a

prominent function by an

international organisation, and

extension of the special

requirements for foreign PEPs to

high risk business relationships

with domestic PEPs and

international organisation PEPs.

• Allowing the adoption of

reasonable risk-based

measures to verify other

identification information of a

natural person customer, so long

as the principal aspects of the

customer’s identity are verified.

• Allowing the use of appropriate

technology for non-face-to-

face account opening with

adequate safeguards against

impersonation risk.

With these proposed updates,

financial institutions are now

exploring how they can enhance their

risk based approach and the use of

technology to make on-boarding

simpler and enhance the overall

customer experience.

Regulatory Hot Issues — Anti-moneyLaundering


Revised Fund Manager Code of Conduct

As part of its objective of enhancing

asset management regulation in

Hong Kong, the SFC issued its

conclusions on revisions to the Fund

Manager Code of Conduct (the

“FMCC”) on 16 November 2017. The

revised FMCC becomes effective on

17 November 2018 and will apply to

persons (i.e. individuals or

corporates), licensed by or

registered with the SFC (“Fund

Managers”), whose business

involves the management of

collective investment schemes

(authorised or unauthorised) and/or

discretionary accounts.

The revised FMCC enhances certain

requirements and codifies new

requirements for Fund Managers, in

relation to risk management,

leverage, custody of assets,

valuation of assets and securities

lending and repo transactions.

Certain key areas have been

highlighted below with respect to

requirements for Fund Managers:

• Effective policies, procedures

and internal controls in a

number of areas should be

established. Fund Managers will

need to revisit their existing

documentation, or establish

documentation, over areas

including risk management,

valuation, conflicts of interest, staff

and insider dealing, collateral

management, to evaluate whether

these are sufficient to comply with

the revised FMCC requirements.

• Internal policies, procedures and

controls should be effective and

subjected to periodic reviews

by management or a functionally

independent party, in order to

ensure continued effectiveness.

• In areas such as risk management,

there can be significant judgement

that needs to be applied as to

whether policies, procedures and

internal controls are effective.

Fund Managers will need to

ensure that appropriately

experienced parties are

involved in the evaluation and

final conclusions on effectiveness.

Open-ended fund companies (“OFCs”)

can now be established in Hong Kong,

which provides the option for Hong

Kong-domiciled open-ended

investment funds to be structured in a

corporate form rather than as unit

trusts. Fund managers now have

increased flexibility in terms of

choices of investment fund vehicles.

These laws and regulations were

pushed out as part of the SFC’s efforts

to enhance market infrastructure to

enable Hong Kong’s sustained growth

as a full-service international asset

management center and a preferred

fund domicile.

The following laws and regulations

allowing for the set up of OFCs

came effect on 30 July 2018 and are

as follows:

• The Securities and Futures

(Amendment) Ordinance 2016,

which provides a legal

framework for a new OFC

structure in Hong Kong,

• Securities and Futures (Open-

ended Fund Companies) Rules and

the Code on Open-ended Fund

Companies, which set out the

proposed detailed legal and

regulatory requirements for the

new OFC vehicle.

Launch of the OFC Regime in Hong Kong

Regulatory Hot Issues — Asset and Wealth Management

PwC · 9Regulatory Updates Newsletter — February 2018

Crypto-assets as an asset class has

been a hot topic within the asset and

wealth management industry in 2018.

This has not escaped the eyes of the

SFC, which issued a Circular on 1 June

2018 highlighting the SFC’s view that

activities such as the development of

new financial technologies, changes to

the business activities to include

trading and asset management

services involving crypto-assets, and

robo-advisory financial services,

represent significant changes which

trigger notification requirements.

At the same time, the SFC advised

intermediaries to discuss these

activities with the SFC before

engaging in them. In addition,

intermediaries are encouraged to

inform the SFC as soon as possible

where a crypto-assets business is

being conducted in Hong Kong by

other entities in the same group as an

intermediary, to enable the SFC to

assess the potential impact of the

group’s crypto-assets business on the

intermediary.

On 28 March 2018, the SFC published

its consultation conclusions on

Proposed Guidelines on Online

Distribution and Advisory Platforms,

with the guidelines coming into effect

on 6 April 2019. With less than a year

until the guidelines come into effect,

intermediaries should use this time

wisely to start their preparations and

to extend their suitability obligations

to their existing or planned online

distribution and advisory platforms.

In the proposed guidelines, the SFC

has specified the requirements for

intermediaries that will offer

investment products on an Online

Platform, including:

• Tailored guidance on the design

and operation of Online

Platforms; and

• Clarifications on how Suitability

Requirements in the sale of

investment products would be

triggered in an online environment

Enhanced fund reporting requirements

The SFC issued a circular on 29 June

2018 to announce the launch of

enhanced fund reporting

requirements for SFC-authorised

funds, with the aim of collecting

enhanced fund data to enhance the

SFC’s ability to perform its

supervisory and regulatory

responsibilities. Details about the

implementation timeline and filing

arrangements have also been

included in the same circular. In

addition to the existing reporting

obligations, the enhanced

requirements will cover periodic

reporting in the following areas:

Types of additional reports required under the

enhanced requirements

Reporting

frequency

First report date First filing deadline

to the SFC

Liquidity profile of the Fund’s assets with reference

to the liquidity categories

Quarterly 30 September 2018 5 November 2018

The Fund’s subscription and redemption amounts Quarterly 30 September 2018 5 November 2018

The Fund’s asset allocation (with reference to a

breakdown of major asset classes by country,

asset quality and listing venue etc.)

Quarterly 31 December 2018 4 February 2019

Securities financing transaction and securities

borrowing transactions of the Fund

Quarterly 31 December 2018 4 February 2019

Notification requirements for crypto-assets and robo-advisors

Online Distribution and Advisory Platforms

Regulatory Hot Issues — Asset and Wealth Management


Cybersecurity

Originally, the Cybersecurity Fortification Initiative driven by the HKMA

required all authorized institutions that had not participated in the phase 1

submission of independent gap assessment in accordance HKMA

Cybersecurity Resilience Assessment Framework (“C-RAF”) to submit the

assessment at the end of 2018 as part of phase 2. Some authorized

institutions have now been put in “phase 3” with a submission deadline that

has been pushed back by one more year, i.e. by the end of 2019.

Other than the timeline, there is no change to the submission format,

assessment methodology and control requirements for C-RAF.

Virtual Banks

Hong Kong is getting ready for the arrival of virtual banks, where customers

would conduct all transactions online. In particular, the HKMA has

announced on 31 August 2018 that it has received 30 applications for the first

batch of virtual bank licences, with the applicants ranging from

telecommunications operators and financial technology (“fintech”)

companies to global banks. The HKMA could issue the first licenses as early

as this year or early next year.

The virtual banks would be subject to almost the same banking regulations as

traditional ones. The key difference between virtual banks and traditional

banks is that they are expected to leverage their fintech experience to offer

digital banking services to customers as well as to promote financial

inclusion, as they would be operated without physical branches.

Regulatory Hot Issues — Technology


At PwC, our purpose is to build trust in society and solve important problems. We’re a network of firms

in 157 countries with more than 208,000 people who are committed to delivering quality in assurance,

advisory and tax services. Find out more and tell us what matters to you by visiting us at

www.pwc.com. This content is for general information purposes only, and should not be used as a

substitute for consultation with professional advisors.

© 2018 PricewaterhouseCoopers Limited. All rights reserved. PwC refers to the Hong Kong member

firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity.

Please see www.pwc.com/structure for further details.

Matthew Phillips

China and Hong Kong

Financial Services Leader

[email protected]

Contact us

http://www.pwc.com/

mailto:[email protected]

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