Position limits and notices of reportable positions

After considering the operational difficulties faced by intermediaries, the SFC will regard it as acceptable for trades transacted in the AH Session to be combined with trades transacted in the regular trading session on the following business day for the purpose of meeting the requirements for reportable positions under the Rules. Nevertheless, intermediaries should monitor the positions during the AH Session to ensure that they comply with the prescribed limits under the Rules and the position limits established by HKFE.

Intermediaries which provide after-hours futures trading services in HKFE products should inform their clients about this reporting arrangement.

A: Fund management companies are subject to the prescribed limits and reporting obligations as long as they hold or control any futures or options contracts as prescribed in the Rules, whether for their own or in respect of the funds. Nevertheless, provided that these management companies do not have discretion in relation to the positions (eg, the day-to-day investment management of the funds has been delegated to investment managers or sub-managers), they are not required to aggregate the funds’ positions, or the funds’ positions with their own positions, if any, in order to comply with the Rules. In this case, the prescribed limits and reporting obligations shall apply separately to the fund management companies’ own positions and each of the funds they hold.

On the other hand, investment managers including sub- or co-investment managers who carry out the investment management functions in respect of the funds are generally required to aggregate the positions for the purpose of compliance. However, if they do not hold or control any positions in the futures or options contracts as prescribed in the Rules, they will not be subject to the relevant prescribed limits and reporting requirements.