It is common for managers with funds authorised by Hong Kong’s Securities and Futures Commission (SFC) also to register their SFC-authorised funds with the Monetary Authority of Macau (AMCM) for sale in Macau, as the registration process is usually quite smooth provided that the applicant manager submits a duly completed set of application documents and has appointed Macau distributor(s) to market its funds. The ongoing obligations for a fund registered with the AMCM are generally not onerous, as the AMCM would expect the funds to comply with the SFC’s requirements in Hong Kong.
Having said that, registration of funds with AMCM does require compliance with ongoing obligations such as making appropriate applications for scheme changes and filings of shareholder notices, constitutive documents and offering documents with the AMCM. Fund houses are reminded to reflect the ongoing obligations applicable to AMCM registered funds in internal policies and procedures. In particular, when a fund house proposes changes to an SFC-authorised fund which is also registered with the AMCM, the Macau application/filing requirements should be taken into account concurrently when assessing the SFC implications.