LAWSQ莮TX.PDFVIP

THE LAWSQÇ~TX 香 會 自市 港 律 Consultation Paper on Proposed Enhancements to the Position Limit Regime and the Associated Amendments to the Securities and Futures (Contracts Limits and Reportable Positions) Rules and Guidance Note on Position Limits and Large Open Position Reporting Requirements The Law Societys Submission The Law Society has reviewed the captioned consultation paper issued by Securities and Futures Commission (“SFC) on about 20 September 2016 , and rendered the following responses to the consultation paper. Question 1a: Do you agree with the proposal to raise the cap on the excess posit的n limit for Hang Seng lndex (HSI) and Hang Seng China Enterprises lndex (“HHI) 戶tures and options contracts from the current level of 50% to 300%? Law Societys response: We agree with the proposal to raise the maximum cap , noting that the SFC wi11 determine at its discretion the cap for a particular Exchange Participant (“四) or EP affiliate. Question 1b: Do you agree with the proposal relating 的 tightening the “adequate 戶nancial capability requirement as set out 的 paragraph 25 of the Consultation Paper? Law Societys response: We have no particular view on the NAV Requirement threshold amount to be used but suggest the SFC may consider whether to keep a lower minimum threshold and then use its discretion to require greater thresholds on a case by case basis. Question 2: Do you have any comments on the proposed exchange tradedfunds (ETF) Market Maker Excess Position Limit, ie, an ETF market ma