Full Analysis of Licensing Requirements for LPF Investment Committee Members in Hong Kong

1. Context

  • The Limited Partnership Fund Ordinance (LPFO) came into force on 31 Aug 2020, positioning Hong Kong as an on-shore hub for private equity and VC funds.
  • Key question: Do Investment Committee (IC) members need an SFC licence? The answer hinges on function, not title.

2. Licensing Triggers

TestExplanation
Dominant-Role TestDoes the individual exercise sole or joint dominant control over investment decisions?
Functional TestIs the individual conducting Type 4 (Advising on Securities) or Type 9 (Asset Management) regulated activity under Schedule 5 of the SFO?
  • No licence required: advisory-only experts, compliance observers, technical consultants without voting powers.
  • Licence required: members with voting or veto rights, anyone materially managing fund assets.

3. Practical Scenarios

RoleFunctionLicence?
External AdvisorMarket insights, no voteNo
GP RepresentativeJoint voting rightsYes
Compliance OfficerObserver, regulatory adviceNo

4. Governance Best Practices

  1. Include at least one RO on the IC for oversight.
  2. Draft clear Terms of Reference delineating voting vs. advisory roles.
  3. Keep detailed minutes of attendance, discussions, and decisions.
  4. Conduct periodic reviews to align governance with evolving business and regulation.

Latest Licences for Sale!

LCS0007 / Type 1 & 4 License / $1.65M / $4.3M NAV / Central PI Advisory Firm

By conradko | May 4, 2025

Key Points: Major Selling Points: Other Details: For more information, please WhatsApp 93472064. Paradox Management Limited is representing the seller and the listed price of $1.65M includes Paradox’s commission. Note: These details are for reference only and may deviate significantly from the actual company. View with caution.

SOLD:IB0015 / Insurance Broker License / General & Long Term Business (including Linked Long Term Business) / Historical FYP US$3.2M+ / Strong Insurance Company Relationships

By conradko | April 23, 2025

Key Points: Major Selling Points: Other Details: For more information or to engage with the seller, please WhatsApp 93472064. Paradox Management Limited is representing the seller and the price shown includes Paradox’s commission.

LCS0080 / Type 1,4,9 License / $4.5M / NAV $4.5M / NO LICENSE CONDITIONS with HSBC & CITIC Bank Accounts

By conradko | April 16, 2025

Key Points: Major Selling Points: Other Details: For more information, please contact via WhatsApp: 93472064. Paradox Management Limited is representing the seller and the price shown includes Paradox’s commission. Please note: These details are for reference only and may deviate significantly from the actual company. View with caution.

LCS0079 / Type 1, 4, 9 License / $2,000,000 + $6,600,000 NAV / No Trading Rights, No Client Assets, Long-Established Company

By conradko | March 26, 2025

Key Points: Major Selling Points: Other Details: For more information or to engage with the seller, please WhatsApp 93472064. Paradox Management Limited is representing the seller and the price shown includes Paradox’s commission. ⚠️ Note: These details are for reference only and may deviate significantly from the actual company. View with caution.

Latest Licences wanted!

BB0080 | SFC Type 1 or 1,4 License | Budget: 2M HKD

By conradko | August 17, 2024

💼 Established mainland Chinese brokerage firm🏦 Specializes in options and margin trading🌐 Seeking to expand into Hong Kong📋 License required: SFC Type 1 or Types 1 and 4💰 Budget: 2 million HKD📈 Commission: 800,000 HKD markup requested Other Details: No current physical presence in Hong KongLooking to acquire an SFC licensed company For more information,…

BB0066 | SFC 1,4,9 | Budget 2.8M

By conradko | August 17, 2024

🔍 Opportunity Alert: SFC Licensed Corporation Sought A mainland private equity fund is on the lookout for an SFC licensed corporation with Types 1, 4, and 9 licenses. This is a unique chance for sellers in the financial sector! Key Details:🏢 Licenses: SFC Types 1, 4, and 9💰 Budget: 2.8M HKD📈 Commission: 800,000 HKD markup…

BB0061 | 🏛️ License: SFC Type 1 | 💰 Budget: HK$2,500,000

By conradko | August 17, 2024

Major Points about the buyer: 📊 SFC Type 1 license required💼 Trading Right needed📈 Margin trading capability preferred🕰️ Company history: 5+ years💰 Budget: HK$2,500,000 Other Details: Buyers include major shareholders of listed companiesReady for immediate SPA signing and deposit paymentWilling to cover transition period operational costsPrefer current RO to stay onCompany name must include “Securities”Buyers…

Paradox Management Limited

Paradox Management Limited, established in 2010 in Hong Kong, specializes in vocational training and licensing support for the finance, banking, and insurance sectors. The company offers personalized training programs, including private sessions and group classes, as well as access to comprehensive exam question banks. Additionally, Paradox Management Limited assists with regulatory compliance, the acquisition and sale of financial entities, and obtaining Money Lender Licenses. Catering primarily to small financial institutions, the company is known for its deep industry expertise, client-focused approach, and proven success in helping professionals excel in their careers.

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