HKSI Paper 6 Exam Guide: Type 9 Asset Managers

Paper 6, Regulation of Asset Management, is the second regulatory paper a responsible officer (RO) needs for Type 9 asset management. If a fund manager or private equity firm is putting you forward as an RO, this is the paper that sits beside Paper 1. Type 9 licensed representatives do not need it.

Getting that distinction right saves a sitting. Getting the exemptions right can save the paper altogether. The SFC lists a full exemption and six conditional exemptions from the regulatory papers, and four of the conditional routes are for ROs only.

The format at a glance

That is about 90 seconds a question. Monthly pass rates over the same twelve months ran from 50.00% (May 2026) to 80.77% (Nov 2025), so roughly four in ten candidates fail. HKSI’s preparation guidance estimates 55 to 85 self-study hours for each regulatory paper. There is no negative marking, so answer every question.

Who needs Paper 6

The SFC’s Guidelines on Competence (October 2024) set two exam requirements for each regulated activity: the local regulatory framework paper (LRP) and the recognised industry qualification (RIQ). For Type 9 they are:

The RIQ is often covered another way. An RO with a degree in accounting, business administration, economics, finance or law, or a qualification such as CFA, CIIA or CFP, needs no RIQ at all (para 4.2.1.2, Option A). The LRP has no such shortcut: a degree or CFA does not remove Paper 6.

Every RO route in para 4.2.1.2 also needs experience as well as papers:

• Relevant industry experience: at least 3 years over the past 6 years (Options A and B, and Option C with the RIQ), or 5 years over the past 8 (Option C with Extra CPT).
• Management experience: 2 years.
• The LRP: a pass in Papers 1 and 6, unless an exemption below applies.

For RO applications to private fund managers, the SFC accepts a wider range of experience as relevant, such as proprietary trading, research and alternative strategies, when the firm serves professional investors only (para 4.1.9(a)).

The four syllabus topics

HKSI’s Paper 6 syllabus has four topics. It publishes no weighting per topic, so treat each as examinable.

Topics 1 and 4 repeat a lot of Paper 1: the SFO, licensing, the Code of Conduct, AML and market misconduct. Topics 2 and 3 go well beyond Paper 1, above all the fund product codes and the Fund Manager Code of Conduct in Topic 3.

Exemptions from Paper 6

Paragraph 4.4 of the Guidelines lets the SFC exempt you from an LRP, fully or on conditions. The SFC decides case by case, and an exemption is tied to your role at a named firm (para 4.4.1.4). The routes that matter most to a Type 9 RO:

For the conditional routes, the 5 CPT hours are a one-off. You take them in the six months before you apply, or within 12 months after approval with an undertaking from you and your firm. A practitioner who left the industry 3 to 8 years ago and returns in the same role can apply under the re-entrant exemption instead (para 4.4.4.1).

A worked example

Mandy has a finance degree, six years as a Type 9 representative at a Hong Kong fund house and two years running its analyst team. Her firm wants her as an RO.

• RIQ: not needed. Her finance degree is Option A.
• Experience: met. She has more than 3 years over the past 6, and 2 years of management.
• LRP: Papers 1 and 6. She passed Paper 1 more than three years ago, but she has stayed licensed, so the SFC can still recognise it (para 4.1.6).
• Paper 6: she can sit it, or ask the SFC for Conditional 3 if her licensed Hong Kong experience exceeds the Option A minimum by 3 recent years. Six years against a 3-year minimum fits that test on its face; the SFC still decides.

How to prepare

• Sit Paper 1 first if you need both. Paper 6 assumes you already know the SFO and the Code of Conduct. Start with the Paper 1 exam guide.
• Spend most of your hours on Topics 2 and 3: the Fund Manager Code of Conduct, the UT Code and the client asset rules. Our Paper 6 page has practice questions by topic.
• Keep a figures sheet: each threshold or deadline next to the code paragraph it comes from.
• Try HKSI’s Paper 6 Sample Practice Test on hksi.org, then our timed mock exams. Book once you score above 80% on a full mock; you must sit within 90 days of enrolling (see how to register).

If you also need the RIQ, the Paper 7 exam guide and our Paper 12 page cover the practical side. Check your route first with the papers checker.

Sources

• HKSI Institute, Licensing Examination overview (paper list, format, pass mark, fees, frequency), Updating Your Study Guides, Guidelines for Examination Preparation, Sample Practice Tests and Pass Rate for the LE in Hong Kong (September 2025 to August 2026): hksi.org, all checked 13 October 2026.
• HKSI Institute, LE Paper 6 syllabus, effective from 12 January 2026, checked 13 October 2026.
• SFC, Guidelines on Competence (October 2024), paras 4.1.5, 4.1.6, 4.1.9, 4.2, 4.3.3.1 and 4.4, checked 13 October 2026.

HKSI Prep is an independent study tool, not affiliated with or endorsed by HKSI Institute or the SFC. The SFC decides every licence and exemption; confirm paper details on hksi.org and the current Guidelines on sfc.hk.