SFC-HKMA Joint Survey on the Sale of Non-exchange-traded Investment Products 2024

Sep 2025

The Securities and Futures Commission (“SFC”) and the Hong Kong Monetary Authority (“HKMA”) published the conducted annual joint survey on the distribution of non-exchange-traded investment products, showing record sales and level of market participation of these products during 2024. The survey reports a 40% surge, reaching a record HKD 6.07 trillion in non-exchange-traded investment product sales in Hong Kong in 2024, reflecting robust market participation and investor confidence.

The SFC and HKMA polled 2,477 responded firms, including 2,368 licensed corporations and 109 registered institutions licensed or registered for Type 1 (dealing in securities), Type 4 (advising on securities) or both regulated activities. The survey covered the sale on non-exchange-traded investment products from 01 January to 31 December 2024 (“reporting period”) by licensed corporations and registered institutions to non-professional investor clients, individual professional investors, and certain corporate professional investors where intermediaries cannot make use of a waiver of the suitability obligation.

The survey indicates that all major non-exchange-traded investment product types recorded “significant” sales growth last year, according to a joint statement issued by the two regulators in September 2025.

According to the finding, sales of authorized collective schemes (“CIS”) grew 76% in 2024. Based on the survey, money market funds remained to be the top-selling CIS, followed by bond funds with an increase of 80% in 2024. Meanwhile, sales of structured products and debt securities increase by 30% and 29% year-on-year, respectively.

In terms of overall transaction amount sold in 2024, the top product type sold by licensed corporation and registered institutions during the reporting period was structured products (HKD 2.567 trillion or 42%), followed by CIS (HKD 2.244 trillion or 37%) and debt securities (HKD 941 trillion or 15%).

Market participants observed a notable improvement in market conditions and investor sentiment throughout 2024. This shift was driven by favourable factors, including supportive policy measures from Mainland authorities, anticipations of monetary easing by major central banks, robust performance in global equity markets, and a more optimistic global economic outlook. These conditions encourage investors with a higher risk tolerance to increase their market exposure and allocate capital towards higher-yield instruments, such as equity linked structured products.

On the other hand, significant downside risks including ongoing political tensions, prolonged regional conflicts, uncertainty surrounding the trade and foreign policies of the new U.S. administration, and the latent risk of a market correction prompted a more risk-averse segment of the investor base to seek shelter in lower-risk, income-oriented products. This included CIS and debt securities, such as money market funds and sovereign bonds.

What to expect from the Regulators?

The SFC and the HKMA will initiate a new round of concurrent thematic review of the distribution of non-exchange traded investment products by intermediaries. The upcoming concurrent thematic review will examine selected intermediaries’ policies and procedures, systems and controls, and management oversight concerning the distribution of CIS. The objectives of this review include evaluating intermediaries’ compliance with the suitability requirement under the Code of Conduct, including their practices in performing product due diligence, conducting suitability assessments and providing information to clients.

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