The Launch of Wealth Management Connect: Does your operating model comply with the operational arrangement?
After more than 18 months since the announcement of the scheme, regulators officially launched in September 2021 the cross-border pilot scheme of Wealth Management Connect (WMC) in the Greater Bay Area (GBA). With the launch, the Hong Kong Monetary Authority (HKMA) has released the detailed arrangements to further facilitate the implementation of the WMC operating model and the framework. The implementation arrangements set out in the circular1 apply to Hong Kong banks that participate in Northbound and Southbound business activities under the WMC Scheme.
It is expected that the regulators — i.e., The People’s Bank of China (PBOC)2 and the HKMA — will enhance the regulatory requirements for industry participants, in hopes of ensuring a smooth implementation and further development of the WMC Scheme.
Understanding the Southbound and Northbound Schemes
To comply with the cross-border requirements of the Scheme, the participating banks will have to adapt and/or develop a fit-for-purpose framework that incorporates an end-to-end process in areas such as client onboarding and account opening, cross-boundary remittance and quota management, product due diligence, controls and supervision, etc.
The Northbound Scheme
Under the Northbound Scheme, eligible investors3 in Hong Kong can invest in eligible wealth management products provided by Mainland China banks participating the WMC Northbound Scheme.
Hong Kong banks must take note of:
Opening of accounts
Hong Kong banks must conduct the initial customer due diligence and investor profiling for the prospect clients to open a dedicated WMC account with their Mainland China partner banks.
How to open an account:
Option 1: Hong Kong banks must transfer the prospect client’s account opening documents to their Mainland China partner banks to facilitate the pre-account opening process with the partner banks; or
Option 2: The prospect clients can directly submit their account opening documents to the Mainland China banks via their online platforms. Once a Mainland China dedicated account is opened, it must be paired with one dedicated WMC account with the Hong Kong banks to form a close-end loop
Money flow quota
The money flow within the two accounts is subject to the quota of net RMB 1 million per person. Separately, the money flow between the Hong Kong banks and their partner banks is subject to the aggregated quota of net RMB 150 billion. Hong Kong banks are expected to maintain proper records of the flow of funds into and out of the dedicated remittance accounts. Mainland China banks are required to record the information in RCPMIS3 before the first remittance, and conduct the remittance in RMB via CIPS4.
Eligible customers can exchange their investment capital from HKD or other currencies to RMB within their Hong Kong accounts.
Purchasing of products
Eligible customers can also purchase the WMC Scheme’s wealth management products via the Mainland China banks’ online platforms, or by visiting the Mainland China banks’ branches in person
Solicitation or recommendation:
At this stage, no solicitation or recommendation to clients is allowed for the purchase of products. Mainland China partner banks may, upon request, provide explanatory information to the customers via phone or their online channels, but cannot proactively invite customers, or travel across the border, to provide investment advisory services.
The Southbound Scheme
Under the Southbound scheme, eligible investors6 in the Guangdong Province can invest in eligible wealth management products provided by Hong Kong banks that participate the WMC southbound scheme.
Hong Kong banks must take note of:
Opening of accounts
Once eligibility is confirmed by the Mainland China banks, prospect clients in Guangdong can apply for an investment account with the Hong Kong banks by attestation (ID&V is done by the Mainland China banks) or by visiting the Hong Kong banks in person.
It is the responsibility of the Hong Kong banks to conduct the customer due diligence and investor profiling, and to ensure proper disclosure of information and risks controls.
Once the Hong Kong dedicated account is opened, it must be paired with one dedicated WMC account in the Mainland Chia banks to form a close-end loop.
Money flow quota
As with the Northbound Scheme, the money flow within the two accounts is subject to the quota of net RMB 1 million per person, whereas the money flow between Hong Kong banks and their partner banks is subject to the aggregated quota of net RMB 150 billion. Similar to the Northbound Scheme, Hong Kong banks participating in the Southbound Scheme should maintain proper records of the flows of funds in to and out of dedicated remittance accounts; while Mainland China banks are required to record the information in RCPMIS before the first remittance and conduct the remittance in Renminbi via CIPS.
Eligible customers should exchange the investment capital from RMB to HKD or other currencies within their Hong Kong accounts.
Purchasing of products
Eligible customers can also purchase the WMC wealth management products via the Hong Kong banks’ online platforms by visiting their branches in person.
Purchasing due diligence
At this stage, it is the responsibility of the Hong Kong banks to continually conduct the product due diligence on the eligibility of the low-to-medium risk products, such as investment products (authorised funds and bonds) and deposits.
Solicitation or recommendation:
At this stage, no solicitation or recommendation is allowed to clients for the purchase of products.
Hong Kong banks to seize the opportunities
Competition for the initial market share
Under the Scheme, eligible investors are permitted to open a pair of dedicated investment accounts. However, banks are required to perform extensive due diligence checks prior to opening the account to ascertain that the investors have not already opened the same type of account with other banks. As a result, high switching costs are embedded to prevent investors from frequently switching between banks. To compete for the initial market share, Hong Kong banks are encouraged to take quick actions to prepare and deploy appropriate strategies to acquire customers as soon as the initial market opens.
Clear cross-border policy
Under the execution-only and non-solicitation rules, more constraints are added to the cross-border business. Banks should invest resources to revamp and implement a fit-for-purpose selling process, and design a WMC Scheme-specific marketing strategy.
A comprehensive cross-border policy and series of trainings and guidance are to be offered to staff at the first and second lines of defence, with robust monitoring on the communication process. It also requires system enhancements in order to capture all the correspondence and communications (such as emails and recording lines) for a clear audit trail. The cross-border policy should cover the end-to-end processes, from investor eligibility checking and client due diligence, to account opening and post-trade activities.
Partnership with Mainland China Banks7
Partnering with Mainland China banks is a crucial requirement to complete the process under the WMC Scheme’s operational model. It also provides additional channels for networking and marketing towards Mainland China clients since this partnership will potentially extend the outreach to the partner banks’ existing client pool. The partnership will allow Hong Kong banks to increase their profitability through higher market exposure and expansion of the business line.
To capitalise on this requirement, banks should develop a holistic partnership strategy, which includes partner identification, clarification of joint priority, definition of the structure and metrics on reviewing the relationships, and forming a dedicated team to manage the relationship with clearly defined roles, responsibilities and sufficient resources to support.
Robust due diligence framework
A robust investment suitability framework and solid capability of product management, including product due diligence and risk assessment, can directly affect the customer experience. Banks should identify the gaps between existing framework and the WMC Scheme-specific handling procedures to derive a WMC Scheme framework that can not only fulfil regulatory requirements, but also be efficient and streamlined enough to ensure a smooth customer journey.
For investment profiling and KYC, banks should work with their partner banks to gather sufficient client information to perform a holistic review and risk assessment on an on-going basis, and at the same time provide customers with sufficient materials and disclosure to facilitate the investment suitability assessment.
All-encompassing sales approach and investor protection
Hong Kong banks should adopt a long-term business strategy that aligns with the WMC Scheme’s requirements on the intended sales approach to facilitate the sales and marketing of its investment products. The HKMA states that the transactions for investors should only be carried out on an execution-only basis and banks are not allowed to solicit or recommend individual products to investors.
For now, banks should focus on promoting and improving the investors’ awareness of their WMC Scheme services and the investors’ rights in accordance with the arrangements. Apart from the regular staff training that the bank conducts to equip frontline staff with the cross-border compliance and product and market knowledge, banks should also pay attention to the complaint handling mechanisms and provide timely follow-ups with the unsatisfied investors.
Digital services and omni channels
Banks should aim to offer readily available digital services and omni channels to customers as the baseline of an end-to-end client digital journey. This is especially important as the COVID-19 pandemic has fuelled the shift towards remote channels, and will only continue to increase investors’ acceptance for a cross-border business model.
Banks should capitalise on this opportunity and invest in a frictionless end-to-end digital journey. The improved digital journey would reduce client’s efforts in travelling to branches, and at the same time, increase client retention.
Current banking strategies observed under WMC
The financial industry in Hong Kong is actively engaged in the participation of the WMC Scheme. At this moment, we have observed some common strategies adopted by banks and other financial institutions, such as asset managers and fund managers, to grow and expand their business within the GBA region.
Define target customer
Leading banks have clearly defined their WMC target customer segments and set up KPIs and business goals towards the WMC scheme or the GBA region.
Most banks see talent acquisition as a critical move to capitalise on the opportunities the WMC Scheme brings. Notably, banks have set aggressive recruitment goals for their client-facing staff and Wealth Management experts to better support high-net-worth clients in Mainland China and Hong Kong by 2025.
Banks are also looking into investments in digital platforms and in-house expertise targeting the Mainland China client segment to facilitate and streamline the client on-boarding, investment advice and product sales processes.
Products and services
Banks are also developing and promoting suitable cross-border wealth management products to align with the expected low-risk requirements laid out by the HKMA for the first batch of product approvals in October 2021.
To facilitate the cross-boundary investment process and prepare the onboarding of eligible products, Hong Kong banks are either in process of exploring potential partnerships or have already built partnerships with Mainland China financial institutions.
How Synpulse can help
With the official launch of the WMC Scheme, banks are gearing up for the roll-out of their strategic plans to seize the opportunities, and equip themselves with the right know-how of the GBA market.
Synpulse brings our in-depth expertise in the private banking and wealth management sector. We combine it with our experience on cross-border solutions implementation and delivering through a highly experienced team with extensive knowledge of the GBA market.
Synpulse supports our clients in defining organisational and system designs, and bringing about the transformation to achieve a highly digital and readily scalable operating model. We provide end-to-end solutions for a digital client journey in cross-border onboarding and pre-trade processes, and ensure the alignment of the risk and control frameworks, across onshore and offshore while complying with regulatory requirements in all jurisdictions.