HKSI Paper 6 General regulatory framework question: Hong Kong shopping malls

HKSI Paper 6General regulatory framework

Kowloon Harbour REIT, authorised by the SFC under s.104, owns mainly Hong Kong shopping malls. Its management company and trustee are in Hong Kong. Which of the following statements are CORRECT? I. Managing the REIT is real estate investment scheme management, a form of Type 9. II. Managing an unauthorised private fund holding only Hong Kong office buildings would also be real estate investment scheme management. III. The REIT's trustee, as its top-level depositary, generally needs a Type 13 licence or registration. IV. If the REIT's property were mainly listed shares instead of real estate, managing it would fall outside Type 9.

A I and II only
B I and III only
C II and III only
D I, III and IV only

Show the answer and explanation

Answer: B. I and III only

Type 9 asset management means real estate investment scheme management or securities or futures contracts management. Real estate investment scheme management is operating a CIS whose property is primarily immovable property and which is authorised under s.104, so statement I is correct and statement II is wrong: an unauthorised fund fails the s.104 limb. Statement III is correct: a REIT is a CIS authorised under s.104 and not an MPF product, so it is a relevant CIS; the SFC says the top-level depositary of an SFC-authorised CIS generally needs Type 13, and the REIT Code accepts a Type 13 depositary as trustee. Statement IV is wrong: managing a portfolio of securities is securities or futures contracts management, which is still Type 9. Source: SFO (Cap. 571) Sch. 5 Pts 1-2 (asset management, real estate investment scheme management, relevant CIS, depositary); REIT Code (October 2024) para 4.3(d); SFC licensing guidance on depositaries (as at October 2026).

Common mistake

Forgetting that real estate investment scheme management needs an SFC-authorised scheme. Private property funds fall outside that limb.

Practise more Paper 6 General regulatory framework questions

Exam-style questions with worked answers, then full timed mocks. Free to start.

Start practising →

Study note: General regulatory framework for asset management HKSI Paper 6 practice questions & mock exams

Related HKSI Paper 6 questions

Victoria Gate Securities Ltd, licensed for Types 1 and 4, posts on its public website an invitation to subscribe for units in a Cayman hedge fund that the SFC has not authorised. Nothing limits the offer to professional investors or to persons outside Hong Kong. What is its position under Part IV of the SFO?The SFC is looking into repeated pricing errors at Silver Bay Income Fund, an SFC-authorised fund. Before any finding, the fund's approved person asks in writing for the fund's authorisation to be withdrawn. How may the SFC respond?Under the Harbour Suites Plan, investors each buy a room in a hotel building. The operator runs the whole building as one hotel; each investor receives the letting income of his own room, so contributions and profits are not pooled. Investors have no day-to-day control. Is the plan a CIS under the SFO?

Build a daily practice habit — a few exam-style questions a day, with worked answers. Free to start.

Start practising →

Original study material mapped to the public HKSI Paper 6 syllabus. Unofficial, not endorsed by HKSI Institute or the SFC. Verify figures and rules against current guidance before relying on them.