Thresholds and investor classes

What is a Singapore accredited investor?

Under section 4A of the Securities and Futures Act, an individual qualifies with net personal assets above S$2 million (the primary residence counts for no more than S$1 million), net financial assets above S$1 million, or income of at least S$300,000 in the past 12 months. The investor must also opt in. The MAS said in February 2025 that the criteria were last updated in 2018.

What is a sophisticated professional investor in Hong Kong?

It is a client eligible for the streamlined suitability approach set out in the HKMA/SFC joint circular of 28 July 2023. Under it, the intermediary need not match each transaction to the client's risk tolerance, objectives and horizon. A law-firm summary of the circular's annex gives a portfolio of HK$40 million or net assets of HK$80 million, excluding the primary residence, as one test. That figure is from a secondary source.

Does meeting a bank's published threshold guarantee an account?

No. Acceptance depends on due diligence: whether source of wealth can be evidenced, the client's country and business, and the bank's risk appetite. Investor classes also carry a trade-off, because being treated as a PI, SPI or AI means some retail protections are simplified or do not apply.

Onboarding and due diligence

What is the difference between source of wealth and source of funds?

Source of wealth is how the client's total wealth was built, for example a business, salary, a share sale or an inheritance. Source of funds is where the specific money entering the account comes from. An HKMA training paper (January 2016) treats source of wealth as part of private-banking due diligence and notes that exact figures are not required. It also states that it is not itself a formal regulatory requirement.

How long does onboarding take?

Usually weeks to months, depending on complexity. Common delays are gaps in the evidence for business income, older assets with no paperwork, multiple tax residences, payment routes that do not match the declared source, and layered company or trust structures whose beneficial owners are hard to identify.

What changed in 2026 for mainland Chinese clients in Hong Kong?

An HKMA circular of 22 May 2026 (the SFC issued a parallel circular to licensed corporations the same day) requires registered institutions, the banks that carry on securities business, to obtain a written declaration when opening an investment account for a mainland individual investor, and to settle only through bank accounts in the investor's own name at eligible banks. Annex 1 of the circular requires the declaration to confirm that funds supporting the investments and related settlements come from lawful sources outside the Chinese Mainland. Annex 2 of the circular states that non-investment functions such as savings, deposits, payments, loans and cards, and corporate and institutional clients, are outside the scope.

Choosing a centre

What is a booking centre and why does it matter?

It is where the account and assets are legally booked and held. It can differ from where the relationship manager sits. The booking centre decides which investor-protection rules and deposit scheme apply and which institution reports under CRS. Some services, such as discretionary mandates at certain banks, are offered only in particular booking centres.

Are private-bank deposits protected?

Only deposits, and only up to set limits. Hong Kong covers HK$800,000 per depositor per member bank from 1 October 2024. Singapore covers S$100,000 per depositor per member, for Singapore-dollar deposits only. Investments, custody assets and, in Singapore, foreign-currency deposits are outside these schemes.

What is Bank of Singapore's relationship with OCBC?

Bank of Singapore describes itself as a wholly owned private-banking subsidiary of OCBC, headquartered in Singapore with a branch in Hong Kong. OCBC's completion announcement of 29 January 2010 records that ING Asia Private Bank was renamed Bank of Singapore when OCBC completed the acquisition. The Hong Kong branch's licence type can be checked on the HKMA register.

Credit

How does a Lombard loan work?

It is credit secured on securities or deposits held at the bank. If collateral value falls below the required margin, the bank makes a margin call; if that is not met, it can sell collateral. HSBC Bank (Singapore) Limited's retail Lombard terms (effective 30 April 2025; not private banking terms) allow liquidation whether or not a margin call has been sent. This is one bank's example. Since October 2021 the HKMA no longer requires share loan-to-value ratios to follow market norms, but it expects prudent limits.

What should I know about premium financing through a private bank?

Banks look at the policy type, insurer, currency, cash value and the client's other assets. Bank of Singapore, for instance, states that its premium financing is for single-premium and fully paid-up policies. In Hong Kong, IA standards have applied to new premium-financed applications since 1 January 2023. In Singapore, LIA guidance says that assigning a policy revokes a revocable nomination.

Fees, structures and tax

Do private banks have to disclose retrocessions and spreads?

In Hong Kong, yes. The SFC Code of Conduct requires monetary benefits to be disclosed before or at the point of sale, with the maximum percentage disclosed where the amount cannot be quantified. Intermediaries closely linked to issuers may not describe themselves as "independent". In Singapore, read the fee schedule and the bank's disclosures under MAS fair-dealing expectations.

Does a Singapore single family office applying for 13O/13U need a private bank account?

For single family office funds approved from 1 August 2026, yes. MAS circular FDD Cir 05/2026 requires at least S$20 million (13O/13OA) or S$50 million (13U) in designated investments and a private banking account with an MAS-licensed financial institution. Family offices that do not claim the incentives have no such condition, and existing awards whose letters carry no account condition need only a banking or private banking account.

Will my private bank account be reported under CRS?

Yes, if you or a controlling person are tax resident in a reportable jurisdiction. Hong Kong has operated its automatic exchange framework since 30 June 2016, and Singapore has exchanged information since September 2018. Mainland China is a partner of both. Tax outcomes depend on your own residence; take professional advice in the relevant jurisdiction.

Do Hong Kong and Singapore levy estate duty or capital gains tax?

Under current law, neither levies estate duty: Hong Kong abolished it from 11 February 2006, and Singapore removed it for deaths on or after 15 February 2008. Neither has a separate capital gains tax. Gains treated as trading income may still be taxable, so individual results depend on facts and tax residence.

Sources and dates

  1. Legislative Council Brief: Securities and Futures (Professional Investor) Rules — Securities and Futures Commission (SFC) · 2002-11
  2. Streamlined approach for compliance with suitability obligations when dealing with sophisticated professional investors — HKMA / SFC · 2023-07-28
  3. Securities and Futures Act 2001, section 4A — Attorney-General's Chambers Singapore (SSO) · 2026-10-22
  4. Individuals; Explore financing solutions; About Us — Bank of Singapore · 2026-10-24
  5. OCBC Bank Launches a Dedicated Private Bank, Bank of Singapore, formerly known as ING Asia Private Bank (Completion Announcement) — OCBC Bank · 2010-01-29
  6. Regulatory Update on AML/CFT: Understanding Source of Wealth Requirements (training material) — Hong Kong Monetary Authority (HKMA) · 2016-01-21
  7. Expected controls for account opening and maintaining relationships with clients with investment accounts (B1/15C, G16/1C) — Hong Kong Monetary Authority (HKMA) · 2026-05-22
  8. Annex 2 – Frequently asked questions for the circular on expected controls for account opening — Hong Kong Monetary Authority (HKMA) · 2026-05-22
  9. Implementation of first phase of enhancement measures of Deposit Protection Scheme — Hong Kong Monetary Authority (HKMA) · 2024-10-01
  10. Deposit Insurance Scheme FAQ — Singapore Deposit Insurance Corporation (SDIC) · 2026-10-23
  11. Credit Risk Management of Share Margin Financing (B1/15C) — Hong Kong Monetary Authority (HKMA) · 2021-10-22
  12. HSBC Lombard Lending Facility Terms and Conditions (retail and Premier client terms, not private banking terms; single-bank example) — HSBC Bank (Singapore) Limited · 2025-04-30
  13. Circular on the supervisory standards and key requirements on the use of premium financing — Insurance Authority (IA) · 2022-04-01
  14. Your Guide to Nomination of Insurance Nominees (2026 v1.0) — Life Insurance Association Singapore (LIA) · 2026-03
  15. FAQ on Code of Conduct (paragraphs 8.3 and 10.2) — Securities and Futures Commission (SFC) · 2017-11-16
  16. Fund Tax Schemes for Family Offices — Monetary Authority of Singapore (MAS) · 2026-09-22
  17. CRS Overview and Latest Developments — Inland Revenue Authority of Singapore (IRAS) · 2026-09-09
  18. Automatic Exchange of Financial Account Information — Inland Revenue Department (IRD) · 2026-10-22