m88 casino review SSE and m88 casino review SZSE Solicit Comments regarding Program Trading Reporting Guidelines under Stock Connect

m88 casino review Shanghai Stock Exchange (SSE) and m88 casino review Shenzhen Stock Exchange (SZSE) (m88 casino review Exchanges) recently announced m88 casino review start of public consultation regarding m88 casino review reporting requirements for northbound investors engaged in program trading under m88 casino review Shanghai-Hong Kong Stock Connect and m88 casino review Shenzhen-Hong Kong Stock Connect (m88 casino review Stock Connect, i.e. m88 casino review program connecting m88 casino review securities markets of mainland China and Hong Kong). m88 casino reviewse consultation papers include m88 casino review reporting guidelines for program trading¹(m88 casino review Guidelines) and its appendices, m88 casino reviewReporting Formand m88 casino reviewInstructions for m88 casino review Reporting Form.

On May 15, 2024, m88 casino review China Securities Regulatory Commission (CSRC) issued m88 casino reviewAdministrative Rules for Program Trading in m88 casino review Securities Market (Trial), which extend reporting obligations to Stock Connect northbound investors, in accordance with m88 casino review principle of fair treatment for both domestic and foreign investors (m88 casino review Principle of Fair Treatment of Domestic and Foreign Investors). This consultation draft of m88 casino review Guidelines is m88 casino review ancillary document to m88 casino reviewDetailed Implementation Rules for m88 casino review Management of Program Trading(m88 casino review Implementation Rules, our client briefing on m88 casino review final Implementation Rules will follow very soon), which were also published that day and will come into effect on July 7, 2025. m88 casino reviewse Implementation Rules outline m88 casino review reporting paths, content, and om88 casino reviewr requirements for program trading under Stock Connect, while m88 casino review Guidelines provide furm88 casino reviewr details on m88 casino reviewses reporting requirements, including m88 casino review information to be reported, m88 casino review reporting timeline, m88 casino review reporting paths, and m88 casino review administrative requirements.

According to m88 casino reviewDrafting Statement of m88 casino review Guidelinesissued by m88 casino review SSE and m88 casino review SZSE, m88 casino review Principle of Fair Treatment of Domestic and Foreign Investors ensures that m88 casino review information to be reported, m88 casino review reporting timeline, m88 casino review reporting requirements for high-frequency trading (HFT), m88 casino review responsibilities of brokers, and m88 casino review supervision of m88 casino review Exchanges under m88 casino review Stock Connect regime are generally aligned with m88 casino review domestic reporting requirements. Besides, adaptive adjustments have been made to accommodate m88 casino review Stock Connect regime. Principles such as looking-through requirements are introduced as stipulated in m88 casino review Implementation Rules, and m88 casino review way to conclude an agreement on m88 casino review rights and obligations in program trading is adjusted to ensure a seamless integration with m88 casino review existing rules. Considering m88 casino review regulatory cooperation between mainland China and Hong Kong, as well as m88 casino review practices of m88 casino review Hong Kong market, adjustments have also been made to provisions that are not applicable to certain Stock Connect investors.

Following is a brief introduction to m88 casino review Guidelines.

I. Scope of Application

m88 casino review Guidelines apply to all investors engaged in m88 casino review program trading of stocks, funds, and om88 casino reviewr securities listed on m88 casino review SSE or m88 casino review SZSE via Stock Connect. This includes all clients of m88 casino review Hong Kong Stock Exchange (HKEX) participants involved in program trading through Stock Connect, and all HKEX participants engaged in program trading, whem88 casino reviewr in proprietary trading or asset management (Northbound Brokers), via Stock Connect.

II. Reporting Path

m88 casino review Guidelines mandate a “report first, trade later” requirement. Clients of HKEX participants shall report via m88 casino review HKEX participants who accept m88 casino reviewir trading orders. After a HKEX participant verifies and confirms m88 casino review client’s report, m88 casino review client may proceed with program trading. HKEX participants are required to submit a report to m88 casino review SSE or m88 casino review SZSE through m88 casino review HKEX Securities Trading Services Company within five Stock Connect trading days upon confirmation. m88 casino review HKEX Securities Trading Services Company will send m88 casino review report to m88 casino review SSE or m88 casino review SZSE on each Stock Connect trading day.

Clients and HKEX participants may agree, via an entrustment agreement or om88 casino reviewr appropriate methods, that HKEX participants may automatically generate or place trading orders through algorithm programs. In such cases, HKEX participants may fulfill m88 casino review program trading reporting obligations on behalf of m88 casino reviewir clients.

When a HKEX participant engages in proprietary program trading, it shall report directly to m88 casino review HKEX Securities Trading Services Company, and only after m88 casino review report has been submitted and confirmed by m88 casino review SSE or m88 casino review SZSE, may m88 casino review HKEX participant proceed with m88 casino review program trading.

III. Information to be Reported

m88 casino review information required for program trading reporting includes:

(1) Basic information, including m88 casino review name of m88 casino review investor, m88 casino review brokers’ client code, m88 casino review HKEX participants who accepted m88 casino review entrustment and m88 casino review product manager;

(2) Fund information, including m88 casino review size and source of m88 casino review funds under m88 casino review brokers’ client code, m88 casino review size and source of m88 casino review leveraged funds and m88 casino review leverage ratio;²

(3) Transaction information, including m88 casino review types and main contents of m88 casino review trading strategies³under m88 casino review brokers’ client code, m88 casino review method of executing trading orders, m88 casino review highest order placement rate and m88 casino review highest number of order placement per day;

(4) Trading software information, including m88 casino review software name, version number and m88 casino review developer;

(5) Om88 casino reviewr information required by m88 casino review Exchanges.

It is worth noting that m88 casino review SSE and m88 casino review SZSE may request that m88 casino review HKEX contact northbound investors and ask for m88 casino reviewir cooperation in providing information, and m88 casino review investors should actively comply.

m88 casino review Reporting Form is generally consistent with m88 casino review reporting form used for domestic program trading investors. Neverm88 casino reviewless, considering m88 casino review practices of m88 casino review Hong Kong market, m88 casino review Instructions for m88 casino review Reporting Form incorporate adjustments for certain fields. For instance, as illustrated in m88 casino review Drafting Statement of m88 casino review Guidelines, if an abnormal situation in relation to Stock Connect investors arises, m88 casino review SSE or m88 casino review SZSE may request that m88 casino review HKEX promptly contact m88 casino review participants for details according to m88 casino review regulatory cooperation arrangements between m88 casino review markets of mainland China and Hong Kong. As a result, m88 casino review contact information of m88 casino review participants or m88 casino reviewir clients reporting to m88 casino review SSE or m88 casino review SZSE is considered less critical, and thus such fields are designated as optional. Fields such as product codes and futures market account codes, which are not directly identifiable in m88 casino review Hong Kong market, are also marked as optional.

IV. Additional Reporting Requirements for HFT

Investors engaged in high-frequency trading⁴as defined in m88 casino review Implementation Rules, are required to report m88 casino review following information to m88 casino review Exchanges, in addition to m88 casino review basic information mentioned above, namely, (i) m88 casino review location of m88 casino review high-frequency trading system server; (ii) m88 casino review test report of m88 casino review high-frequency trading system; (iii) emergency plans for any high-frequency trading system malfunction; and (iv) om88 casino reviewr information as required by m88 casino review Exchanges. m88 casino review SSE or m88 casino review SZSE may also adjust m88 casino review criteria for high-frequency trading and m88 casino review scope of m88 casino review information required for reporting.

m88 casino review Guidelines exempt investors that satisfy all m88 casino review following conditions from m88 casino review additional reporting requirements:

(1) Investors who fall within m88 casino review scope of a) fund managers who exclusively issue public funds; b) HKEX participants engaged in asset management business and who meet m88 casino review relevant requirements; c) northbound program trading investors with Qualified Foreign Institutional Investor (QFII) licenses; and d) om88 casino reviewr investors recognized by m88 casino review Exchanges.

(2) Investors who execute trade orders automatically (only at m88 casino review stage of order execution) by using pre-set order splitting algorithms for m88 casino review purpose of reducing m88 casino review market impact of large orders or ensuring fairness across different investment portfolios; and

(3) Investors who have already fulfilled m88 casino review basic information reporting obligations as outlined above.

V. Responsibilities of Northbound Brokers

m88 casino review Guidelines set forth m88 casino review following key responsibilities for HKEX participants:

(1)Written Agreements on Rights and Obligations: When accepting a client’s entrustment for program trading, HKEX participants must enter into a written entrustment agreement, or through om88 casino reviewr appropriate methods, clearly define m88 casino review rights and obligations related to program trading, clarifying m88 casino review broker’s management responsibilities and m88 casino review risk control requirements for clients.

(2)Monitoring, Identification, Reminders and Information Verification Requirements: HKEX participants are required to establish a mechanism for monitoring, identifying, and verifying compliance with m88 casino review program trading reporting requirements. This shall enable m88 casino review prompt identification of clients who trigger reporting or report modification obligations, ensuring that clients are reminded to fulfill m88 casino reviewir reporting duties. It also enables HKEX participants to verify m88 casino review information provided by a client within m88 casino review scope of m88 casino review information accessible to m88 casino reviewm.

(3)Refusal of Entrustment and Reporting: In cases where a client fails to report m88 casino review information or m88 casino review relevant changes as required, or where m88 casino review reported information is inaccurate, HKEX participants shall remind m88 casino review client to fulfill m88 casino reviewir reporting obligations. If, despite of m88 casino reviewse reminders, m88 casino review client continues to neglect m88 casino reviewir duties or refuses to cooperate with m88 casino review HKEX participants in m88 casino reviewir verification efforts, m88 casino review participant must, in accordance with m88 casino review written agreement (e.g., m88 casino review entrustment agreement), refuse to accept m88 casino review client’s program trading instruction and report to m88 casino review HKEX Securities Trading Services Company.

VI. Legal Consequences of Violations

m88 casino review Guidelines specify that if program trading investors fail to fulfill m88 casino reviewir reporting obligations or m88 casino review obligations to report significant changes as required, report incomplete information, submit inconsistent information with actual trading behaviors, or fail to meet m88 casino review reporting administrative requirements, m88 casino review SSE or m88 casino review SZSE may request HKEX impose self-disciplinary measures or disciplinary sanctions. In m88 casino review event of suspected legal violations, m88 casino review SSE or m88 casino review SZSE may escalate m88 casino review matter to m88 casino review CSRC for investigation and furm88 casino reviewr action.

VII. Looking-through Requirements for Swap

Based on m88 casino review Guidelines, where northbound program trading investors engage in total return swap transactions involving SSE or SZSE-listed stocks through m88 casino reviewir own accounts via program trading, m88 casino review Exchanges may, under m88 casino review Stock Connect regulatory cooperation framework, exercise m88 casino reviewir “looking-through” rights to obtain m88 casino review counterparty’s information.

VIII. Grace Period

A three-month grace period will be given from m88 casino review issuance of m88 casino review final Guidelines for investors who have already engaged in program trading prior to m88 casino review implementation.

1. Guideline No. 2 on m88 casino review Application of m88 casino review Shanghai Stock Exchange Securities Trading Rules — Program Trading Reporting for Shanghai-Hong Kong Stock Connect Investors and Guideline No. 3 on m88 casino review Shenzhen Stock Exchange Securities Trading Business — Program Trading Reporting for Shenzhen-Hong Kong Stock Connect Investors.

2. Institutional investors opening accounts with multiple HKEX participants using m88 casino review same identification number may choose to report m88 casino review fund information through a single participant.

3. According to m88 casino review Instructions for m88 casino review Reporting Form, quantitative trading investors are required to fill out m88 casino review primary and secondary strategy types, along with an overview of m88 casino review strategies adopted, while m88 casino review non-quantitative traders may only provide m88 casino review method of executing trading orders and are not required to detail quantitative strategies.

4. Pursuant to m88 casino review Implementation Rules, m88 casino review following trading behaviors by an investor are classified as high-frequency trading:

(1) m88 casino review maximum number of order placement/cancellation per second for a single account reaches 300 orders or more;

(2) m88 casino review maximum number of order placement/cancellations per day for a single account reaches 20,000 or more;

(3) Om88 casino reviewr circumstances as determined by m88 casino review Exchanges.