The SFC Licensing Boundary for Single Family Offices: Activity, Not Label

Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.

activity-based licensing

activity-based licensing must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. The board should identify a named owner, the authority under which that person acts, the evidence relied upon and the point at which specialist advice is required. A control is not complete merely because a policy exists: the record must show how the control operated, who challenged it and how exceptions were closed. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

activity-based licensing must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. A practical file should distinguish source documents from management assertions, record the date and provenance of each item, and preserve the reasoning that connects evidence to a decision. This makes the position reviewable by a successor, counterparty or adviser without reconstructing events from fragmented correspondence. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

activity-based licensing must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. Implementation should be proportionate to the structure. Smaller offices may combine roles, but they should not combine incompatible approvals without a documented compensating review. Larger arrangements need a controlled register, review calendar, escalation thresholds and evidence of closure. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

single-family versus multi-family office

single-family versus multi-family office must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. A practical file should distinguish source documents from management assertions, record the date and provenance of each item, and preserve the reasoning that connects evidence to a decision. This makes the position reviewable by a successor, counterparty or adviser without reconstructing events from fragmented correspondence. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

single-family versus multi-family office must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. Implementation should be proportionate to the structure. Smaller offices may combine roles, but they should not combine incompatible approvals without a documented compensating review. Larger arrangements need a controlled register, review calendar, escalation thresholds and evidence of closure. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

single-family versus multi-family office must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. The board should identify a named owner, the authority under which that person acts, the evidence relied upon and the point at which specialist advice is required. A control is not complete merely because a policy exists: the record must show how the control operated, who challenged it and how exceptions were closed. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

The value of governance evidence lies not in document volume, but in whether the next decision-maker can understand, review and carry it forward.

discretionary investment authority

discretionary investment authority must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. Implementation should be proportionate to the structure. Smaller offices may combine roles, but they should not combine incompatible approvals without a documented compensating review. Larger arrangements need a controlled register, review calendar, escalation thresholds and evidence of closure. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

discretionary investment authority must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. The board should identify a named owner, the authority under which that person acts, the evidence relied upon and the point at which specialist advice is required. A control is not complete merely because a policy exists: the record must show how the control operated, who challenged it and how exceptions were closed. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

discretionary investment authority must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. A practical file should distinguish source documents from management assertions, record the date and provenance of each item, and preserve the reasoning that connects evidence to a decision. This makes the position reviewable by a successor, counterparty or adviser without reconstructing events from fragmented correspondence. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

holding-out and scope controls

holding-out and scope controls must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. The board should identify a named owner, the authority under which that person acts, the evidence relied upon and the point at which specialist advice is required. A control is not complete merely because a policy exists: the record must show how the control operated, who challenged it and how exceptions were closed. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

holding-out and scope controls must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. A practical file should distinguish source documents from management assertions, record the date and provenance of each item, and preserve the reasoning that connects evidence to a decision. This makes the position reviewable by a successor, counterparty or adviser without reconstructing events from fragmented correspondence. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

holding-out and scope controls must be addressed within the full governance context of “The SFC Licensing Boundary for Single Family Offices: Activity, Not Label”. Implementation should be proportionate to the structure. Smaller offices may combine roles, but they should not combine incompatible approvals without a documented compensating review. Larger arrangements need a controlled register, review calendar, escalation thresholds and evidence of closure. For this topic, the working file should answer the control proposition—Use an activity-based analysis of regulated activity, supported by records of the business model, authority and persons served.—and separately record ownership, timing, evidence, exceptions and review outcomes.

Limitations

This article provides general governance information only. It is not legal, tax, accounting, investment, regulatory or fiduciary advice. Facts, jurisdictions, documents and professional duties alter the analysis; qualified relevant advisers should confirm the position before action is taken.

Primary-source register

Hong Kong Securities and Futures Commission — Family Offices FAQs
SFC — Do you need a licence or registration?