The Securities and Futures Commission’s (“SFC”) consultation conclusions (“Consultation Conclusions”) on the proposed Guidelines for Market Soundings (“Guidelines”) are now in force since 2 May 2025, meaning Licensed Corporations (“LCs”) or Registered Institutions (“RIs“) should have already reviewed and updated their internal policies, procedures and controls to ensure full compliance.

Where this has not yet been completed, a gap assessment must be conducted immediately to address any deficiencies in policies, procedures, and associated controls. Additionally, relevant staff including key personnel involved in market soundings must be trained on the updated requirements.

Looking ahead, firms should aim to schedule a follow-up review in Q4 2025 to assess the design and operating effectiveness of the implemented controls to ensure they are functioning as intended. Given the potential regulatory risks associated with non-compliance, firms must act promptly to close any gaps and plan proactively for the upcoming review to ensure the new regime is properly embedded in practice.

This is a joint webinar with Private Wealth Management Association (PWMA), the key topics to be covered include:

• Key requirements and scope of application
• Implications for buy-side and sell-side firms
• How to implement the requirements, including key control enhancements required
• Industry insights and views of sound practice
• Remaining areas of uncertainty and how to navigate key risks and challenges
• Implementation timeline and immediate steps firms should be taking

Senior management including MICs, ROs, Directors, Compliance Officers, Surveillance Officers and licensed individuals in the business/front-office involved in conducting market soundings from LCs or RIs (on both the buy-side and sell-side).

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