Securities and Futures Commission (SFC) licensed companies with a financial year end of 31 December need to submit the new form of Business and Risk Management Questionnaire (BRMQ) to the SFC by 30 April 2020 (together with their audited accounts).
As mentioned in our January newsletter, the SFC overhauled the BRMQ in 2019. The new form is long so although most of the questions are multiple choice it is taking some clients a long time to finalize it.
As part of its COVID-19 response strategy, the SFC issued a circular in February followed by FAQs in March reminding licensed companies to apply for a deadline extension for submitting audited accounts etc. if they anticipate delays. These applications involve a formal application form and the payment of a fee. The SFC Licensing Handbook suggests that deadline applications be submitted at least one month before the relevant deadline but we would expect the SFC to be pragmatic in handling applications to extend the deadline for submitting BRMQs this year, both because of the COVID-19 outbreak but also because this is the first time most firms are having to use the new form. However, if you think your company may not be able to meet the submission deadline, you should file an extension application urgently.
Deacons can assist firms with the new BRMQ and in submitting deadline extension applications so please let us know if we can help.