Compliance Outsourcing Plans for HK SFC Regulated Asset Managers (Type 4, Type 9)

It's a comprehensive solution where we manage the essential elements of your firm's compliance program. We act as an extension of your team, handling the day-to-day execution of your compliance obligations, including maintaining policies and procedures, conducting surveillance, performing testing, managing filings, and providing ongoing advice.

The fundamental difference lies in execution versus advice. While traditional compliance consultants typically provide guidance, frameworks, templates, and recommendations – leaving the actual administration and day-to-day operational tasks of the compliance program to your internal team – our Compliance Outsourcing service takes on that additional operational burden. We actively manage and execute key components of your compliance program, handling tasks like surveillance monitoring, filings preparation, attestation collection, and routine testing. This significantly reduces the day-to-day workload and worry for your team.

Furthermore, the quality and effectiveness of traditional consulting can often vary significantly depending on the experience, bandwidth, and approach of the specific individual consultant assigned to your firm. We mitigate this variability by pioneering a uniform, tech-enabled service model. This is also how we are able to deliver more, and higher quality, services at highly competitive rates.

This ensures a reliable, high-quality level of service delivery across all clients, focused on the practical administration of your compliance program, rather than just providing advice that you then need to implement yourself.

Our base Compliance Outsourcing packages (Startup, Essential, Institutional) are specifically designed to meet the requirements for firms regulated by the Hong Kong Securities and Futures Commission (SFC). We understand that many firms have cross-border considerations, particularly with the US. Therefore, we offer add-on support for firms operating as US Exempt Reporting Advisors (ERAs) and/or exempt Commodity Pool Operators (CPOs). This additional support includes managing the specific filing requirements associated with these statuses (e.g., relevant sections of Form ADV, CPO-PQR filings where applicable). Pricing for this supplementary US jurisdictional support starts at $500 per month, in addition to the base package fee, reflecting the additional regulatory complexity and filing obligations. Please contact us to discuss your specific cross-jurisdictional needs.

Our standard outsourcing service focuses on providing the operational support and expertise to your designated manager-in-charge of compliance. We typically do not include providing the named CCO as part of the standard package, as the ultimate regulatory responsibility remains with the firm. However, we can discuss options for interim or fractional CCO support services separately if needed.

This is a key aspect of our service design. Depending on the agreed-upon service level, we provide comprehensive Governance and Oversight reports on a monthly or quarterly basis. These detailed reports document all compliance activities performed (e.g., surveillance checks, tests conducted, policies updated, filings submitted), summarize findings, highlight any escalated issues, track remediation efforts, and note upcoming deadlines. These reports serve as crucial evidence for your CCO and management to demonstrate active supervision and fulfill your firm's regulatory obligation to oversee outsourced functions effectively.

Expertise: Access to a team of experienced compliance professionals with deep regulatory knowledge and industry best practices.
‍Cost-Effectiveness: Often more economical than hiring, training, and retaining dedicated full-time compliance staff, especially considering salaries, benefits, and technology costs.
‍Scalability: Easily scales up or down based on your firm's growth, complexity, or regulatory changes without hiring/firing cycles.
‍Focus: Allows your internal team (including principals and portfolio managers) to focus on core business activities like investment management and client relationships.
‍Independence: Provides an objective perspective for compliance testing and oversight.

We establish clear communication protocols with email as the primary and preferred point of contact. You will have a dedicated email address (i.e., 'yourfirm@generis.ai') for all needs related to your package. We will also hold regular check-in calls (monthly or quarterly based on the plan) and scheduled meetings for reporting, testing results, and annual reviews.

Data security and confidentiality are paramount. We employ robust technical and operational safeguards, including secure data handling protocols, access controls, encryption, and non-disclosure agreements (NDAs) with all staff. We adhere to industry best practices for cybersecurity and data protection.

We act as your primary support and coordination point. We assist in gathering requested information, drafting responses, preparing your team for interviews, and managing communications with regulators under your direction. While the ultimate responsibility lies with your firm, we provide the expertise and manpower to navigate these events smoothly.

As per regulatory requirements, the registered firm and its designated MIC retain ultimate responsibility for compliance. Our role as an outsourced provider is to implement, manage, and advise on the compliance program based on agreed-upon procedures and industry standards. We maintain professional liability insurance, but the firm holds the regulatory accountability. Our detailed Governance and Oversight reporting provides essential documentation to assist your MIC and leadership in demonstrating effective supervision of the outsourced activities.