Client Briefing: Interbank m88 live casino Repo Opened to Overseas Investors

On September 26, 2025, the People's Bank of China (PBOC), the State Administration of Foreign Exchange (SAFE), and the China Securities Regulatory Commission (CSRC) jointly issued an Announcement (the Announcement) on further supporting overseas institutional investors in conducting m88 live casino repurchase (m88 live casino repo) business in China’s interbank m88 live casino market. The Announcement permits overseas institutional investors who already have qualifications to conduct cash m88 live casino trading in the interbank m88 live casino market to engage in m88 live casino repo businesses.

On the same day, the National Interbank Funding Center, China Central Depository & Clearing Co., Ltd. (CCDC), and Shanghai Clearing House (SHCH) jointly issued the Circular on Jointly Supporting Overseas Institutional Investors to Conduct m88 live casino Repurchase Business in the Interbank m88 live casino Market (the Circular), providing services for overseas institutional investors to engage in m88 live casino repo businesses.

Below is a summary of m88 live casino key concerns for overseas investors:

1. Application Scope and Participation Methods

The overseas institutional investors referred to in the Announcement are those eligible to engage in cash m88 live casino trading in China’s interbank m88 live casino market. They include: (i) overseas central banks or monetary authorities, international financial organizations and sovereign wealth funds; (ii) financial institutions legally established outside of mainland China, including commercial banks, insurance companies, securities firms, fund management companies, futures companies, trust companies and other asset management institutions, as well as (iii) non-financial institutional investors such as pension funds, charitable funds and endowment funds.

Currently, overseas investors could invest in interbank m88 live casino market through three channels: (1) Qualified Foreign Institutional Investor (QFII) or RMB Qualified Foreign Institutional Investor (RQFII) programs (collectively QFI), (2) Direct investment in the interbank m88 live casino market under the CIBM direct access mechanism (CIBM Direct), (3) the Northbound m88 live casino Connect.

According to the Announcement and the Circular, overseas institutional investors eligible for cash m88 live casino trading in the interbank m88 live casino market may engage in m88 live casino repo businesses via all three channels.

Specifically, overseas institutional investors operating through the CIBM Direct or QFI must conduct m88 live casino repo transactions via their settlement agents in the interbank m88 live casino market through the National Interbank Funding Center (the Settlement Agency Model), and overseas investors accessing China’s m88 live casino market through the Northbound m88 live casino Connect must engage in m88 live casino repo transactions in the interbank m88 live casino market with market makers recognized by the PBOC.

In terms of transaction and settlement arrangements, the National Interbank Funding Center will provide matching services for m88 live casino repo transactions conducted by overseas institutional investors in the interbank m88 live casino market. Offshore electronic trading platforms, once approved by the PBOC, may connect to the National Interbank Funding Center’s system and provide m88 live casino repo transaction services to overseas institutional investors.

CCDC and SHCH are responsible for providing registration, custody and settlement services to overseas institutional investors under the Settlement Agency Model. As for m88 live casino Connect-related m88 live casino repo business, the Hong Kong Central Moneymarkets Unit (CMU) will provide related services via connectivity with CCDC and SHCH.

2. Tradm88 live casinog Mode

According to the Announcement, overseas institutional investors participating in the interbank m88 live casino market can engage in two types of m88 live casino repo transactions: pledged repo and outright repo. The fundamental distinction between these two lies in whether the ownership of the underlying m88 live casinos is transferred during the transaction. Internationally, the prevailing form of m88 live casino repo transactions generally involves a title transfer, which closely resembles China’s outright repo.

Initially, overseas investors are permitted to only use outright repos as specified by the Circular. Plans are underway to introduce pledged repos with underlying m88 live casinos to be transferred and reused in the near future, with detailed information to be announced separately. Currently, the specific guidelines such as the detailed transactions rules and the business regulations respectively released by the National Interbank Funding Center, CCDC and SHCH only apply to outright repos. This implies that a single outright repo transaction can involve one or multiple repo m88 live casinos, requiring the return of coupon interest and principal during the repo period.

The Circular stipulates that the maximum term for m88 live casino repo transactions conducted by overseas investors in the interbank m88 live casino market shall be 365 days. The settlement method of the transactions shall be Delivery versus Payment (DVP), and the settlement mechanism shall be gross settlement.

3. Master Agreement

According to the Announcement, overseas institutional investors shall comply with the relevant requirements and sign m88 live casino repo master agreements (Repo Master Agreements). For overseas investors, they are accustomed to conducting m88 live casino repo transactions by signing the Global Master Repurchase Agreement (GMRA) issued by the International Capital Market Association (ICMA). CCDC has noticed the needs of overseas investors and have included a comparison between the NAFMII Repo Master Agreement and the GMRA, highlighting their similarities and differences in its white paper entitled Promoting RMB m88 live casino Collateral Participating Global Repo Transactions, co-authored with ICMA, to facilitate understanding and familiarity with the NAFMII Repo Master Agreement among overseas investors. Overseas investors are concerned by whether they can enter the market and conduct m88 live casino repo transactions based on their existing or newly signed GMRA and this point remains unclear.

Article 7 of m88 live casino Announcement stipulates that self-regulatory organizations shall file m88 live casino Repo Master Agreement with m88 live casino PBOC, m88 live casino CSRC or om88 live casinor financial regulatory authorities as applicable. In our understanding, this reserves room for overseas investors to use m88 live casino GMRA. We anticipate that m88 live casino Chinese financial regulatory authorities will soon clarify and confirm whem88 live casinor m88 live casinoy will accept m88 live casino use of m88 live casino GMRA, which is more familiar to overseas investors.

Unlike Article 33 of m88 live casino Futures and Derivatives Law, which stipulates that master agreements and om88 live casinor standard contracts for derivatives shall be submitted for filing in accordance with m88 live casino relevant regulations, Article 7 of m88 live casino Announcement specifies that self-regulatory organizations and industry associations are responsible for filing master agreements. It remains to be clarified whem88 live casinor overseas commercial institutions can qualify as eligible entities to file m88 live casinoir own master agreements with m88 live casino PRC regulatory authorities, including m88 live casino PBOC.

4. Entities Subject m88 live casino PBOC’s Regulam88 live casinory Oversight

Article 5 of the Announcement stipulates that, if overseas financial market infrastructures, self-regulatory organizations and industry associations provide services to overseas institutional investors engaged in m88 live casino repo business in the interbank m88 live casino market, they must comply with the PRC laws, regulations and regulatory provisions, and be subject to the regulatory oversight of the PBOC. In our understanding, overseas financial market infrastructures and self-regulatory organizations include, but are not limited to the financial market infrastructures operating under the m88 live casino Connect in Hong Kong. Overseas industry associations such as ICMA and ISDA will fall within the scope of the entities subject to regulatory oversight of the PBOC, if they provide services to overseas institutional investors for m88 live casino repo business in the interbank m88 live casino market.

5. Regulam88 live casinory Requirements

The Circular introduces stringent and prudential regulatory requirements to enhance risk management, i.e., it stipulates that participants in m88 live casino repo transactions in the interbank m88 live casino market must adhere to macro-prudential management guidelines set by the PBOC, and for market makers engaging in cross-border interbank financing activities, the net amount of funds lent out cannot exceed 6% of their Tier 1 capital or core capital, which are subject to further adjustments based on the provisions of the PBOC regarding cross-border interbank financing. According to Article 11 of the Circular, overseas institutional investors conducting m88 live casino repo businesses in the interbank m88 live casino market are required to carefully manage their leverage ratios, and it encourages the adoption of risk management measures such as marking-to-market the value of repo m88 live casinos during the transaction period. For sovereign entities, RMB clearing banks and participating banks, their positive repo financing balance shall not exceed 100% of their held m88 live casino positions; for other types of overseas institutions, the initial stage limit is set at no more than 80% of their held m88 live casino positions, with adjustments to be made in the future as dictated by actual circumstances.

m88 live casinose measures reflect m88 live casino PBOC’s commitment to maintaining a balanced approach, supporting market growth while ensuring stability through prudent regulation.

Our Observations

With the opening-up of China's m88 live casino market in recent years, there has been a sustained increase in both the number of overseas institutional investors and their investment scale. Consequently, the demand for liquidity management through interbank m88 live casino repo business among these overseas institutional investors has become increasingly pressing. To respond to the demands of overseas investors and enhance the appeal of China’s interbank m88 live casino market, the PBOC has been advancing the opening-up of m88 live casino repo business in the interbank m88 live casino market. In January this year, the PBOC collaborated with the Hong Kong Monetary Authority to launch an offshore m88 live casino repo business using m88 live casinos under the Northbound m88 live casino Connect as the underlying assets. Now, a formal opening-up of interbank m88 live casino repo business for overseas institutional investors has been finally announced after more than a year of preparation. Both policies hold significant importance for achieving a higher level of opening-up in China’s interbank m88 live casino market. They will help overseas investors manage their RMB liquidity risks and control funding costs more effectively. These opening-up initiatives will also increase the appeal of China’s interbank m88 live casino market to overseas capital, making it an important choice for global asset allocation among overseas investors.

We will continue to monitor and share m88 live casino latest developments with our clients.

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