Private Banking Thresholds and Services: What PI, SPI, AI and the US$5 Million Bank Minimum Each Mean

A private banking threshold is really two separate things layered together. The first is statutory investor classification: the Professional Investor (PI) and Sophisticated Professional Investor (SPI) in Hong Kong and the Accredited Investor (AI) in Singapore. This determines which products a client may access and which protections apply. The second is the bank's own commercial minimum, such as the "US$5 million in investable assets" shown on some private banks' websites, which determines whether the bank is willing to take the client on. The two come from different sources and are calculated differently; one cannot stand in for the other.

The two layers at a glance: statutory tests and published bank minimums

Whenever you see a claim about a "private banking threshold", first ask whether it is a statutory classification or one bank's commercial criterion. The two often appear together. OCBC's Premier Private Client tier, for example, requires S$1.5 million in new funds deposited or invested and accredited investor status (OCBC website, checked 23 October 2026).

Hong Kong professional investor (PI): an individual portfolio of at least HK$8 million

Hong Kong's professional investor definition comes from the Securities and Futures Ordinance and its subsidiary legislation, the Securities and Futures (Professional Investor) Rules (Cap. 571D). Under section 3 of the Rules, an individual holding, alone or with associates in a joint account, a portfolio of not less than HK$8 million may be treated as a professional investor. For a trust corporation the threshold is total trust assets of at least HK$40 million; for a corporation or partnership it is a portfolio of at least HK$8 million or total assets of at least HK$40 million. A portfolio means securities, certificates of deposit and money held by a custodian, among others; real estate does not count. The scope of what can be counted was amended in 2018.

PI status matters in practice in two ways:

1. Wider product access: some funds, bonds and structured products that are offered only to professional investors and are not authorised by the SFC for public offer can be marketed only to PIs. Their offering documents do not go through the review process that applies to public offers.
2. Changed level of protection: individual PIs remain subject to the suitability requirements of the Code of Conduct, but the protections attached to public offers no longer cover the product itself. A joint HKMA–SFC circular of 28 July 2023 adds a streamlined approach for PIs who meet higher standards; see the next section.

Banks usually ask clients to prove portfolio size with statements or custody confirmations and review PI status periodically.

Hong Kong sophisticated professional investor (SPI): the 2023 streamlined approach

SPI is not a new statutory investor category. It is the "Streamlined Approach" introduced by a joint HKMA–SFC circular on 28 July 2023 for individual PIs who meet higher standards. The circular states that under this approach, intermediaries need not, at the level of each transaction, match the product against the SPI's risk tolerance, investment objectives and investment horizon, nor assess knowledge, experience and concentration risk trade by trade; product features and risk disclosures may be provided once in advance. Intermediaries must at the same time maintain effective systems and controls to prevent abuse and to identify red flags such as unusually large transactions.

The eligibility tests are set out in Annex 1 to the circular. According to law firm Charltons' summary of the annex (secondary source, 8 August 2023), the financial test is a portfolio of at least HK$40 million, or net assets (excluding the principal residence) of at least HK$80 million. The client must also pass a knowledge or experience test and must not have a "conservative" investment objective; transactions must fall within the product classes and streamlined limits the client has chosen; the intermediary must enter into a written agreement with the client and review it at least once a year.

According to an article by the HKMA Chief Executive dated 4 August 2025, seven private banks had adopted the approach by June 2025 and another 13 planned to do so. For the client, opting for SPI treatment means giving up trade-by-trade suitability assessment: execution is faster, and more of the responsibility for judgement shifts back to the client.

Singapore accredited investor (AI): one of three tests, plus an opt-in

Singapore's accredited investor definition is in section 4A of the Securities and Futures Act (SFA). An individual qualifies by meeting any one of the following:

Meeting the criteria is not enough: the investor must expressly opt in before a financial institution may treat them as an AI, and the client may later opt out. A MAS written parliamentary reply of 5 February 2025 noted that the AI eligibility criteria were last updated in 2018.

An AI can access products offered under exemptions without a prospectus, and some disclosure and protection requirements for retail clients no longer apply. As with the Hong Kong PI, this is a trade of protection for product access.

Examples of published private banking minimums

The table below lists only published criteria at the private banking tier. All are commercial minimums, not regulatory requirements:

Priority banking and private client tiers below private banking are retail banking segments; a bank-by-bank summary is on the sister site's priority banking and private banking thresholds guide at bankaccount.sg.

The definition of "investable assets" varies by bank. Whether deposits, policy cash values or assets held at other banks count depends on the bank's own explanation. Meeting the criterion only means the application can be reviewed; account opening still depends on due diligence, covered in Private bank onboarding and KYC. For how the institutions differ in positioning, see Major private banks in Hong Kong and Singapore.

Hong Kong: how to obtain a written criterion you can check

When researching, this site found that most Hong Kong private banks do not publish a uniform entry amount on their websites. The criterion is usually explained by the relationship manager in initial conversations and may differ by booking centre, client location and product needs. To make the criterion verifiable and comparable on the same basis as Singapore, you can ask the bank to answer in writing:

1. What the entry criterion is based on: investable assets, assets held with the bank, or newly transferred funds, and whether there is a deadline for reaching it.
2. Which assets count: deposits, securities, funds, policy cash values, assets custodied at other banks, and assets held through companies or trusts.
3. What happens if assets fall below the criterion: transfer to another client tier, additional fees, or termination of the private banking relationship.
4. Whether PI status is assessed at account opening, which statements serve as portfolio evidence, and whether SPI treatment is assessed separately.
5. Whether the threshold and available services differ when the same bank books the account in Hong Kong or in Singapore.

A written answer avoids treating verbal statements as bank policy and makes it easier to check services and fees later.

Services available once the threshold is met

Similar service menus do not mean every client can use every service. Some services are limited to particular booking centres or client tiers; for how the booking location matters, see Booking centre: Hong Kong or Singapore.

Common misconceptions

1. "Once my assets reach the threshold, I can open an account." The threshold is only an entry condition. A bank may decline a relationship on grounds of risk appetite, the source of wealth explanation or the client's location, without giving reasons.
2. "PI/AI is a premium status." In substance, these classifications reflect the regulator's view that the client can bear more risk, so some protections no longer apply. Before opting in, ask the bank to state in writing which protections you will lose.
3. "Hong Kong's HK$8 million is a higher threshold than Singapore's S$1 million." The two centres measure different things. The PI test looks at the portfolio, whereas the AI test has three routes: net assets, financial assets and income. Converting one into the other and comparing is meaningless.
4. "The SPI threshold is in statute." SPI comes from a regulatory circular and its annex and is an arrangement for discharging suitability obligations; the financial test figures cited on this site come from a law firm summary (secondary source).
5. "Banks with higher thresholds are safer." A threshold reflects the bank's client positioning. It bears no relation to capital strength, regulatory compliance or the safety of assets.

How thresholds and services apply in a given case depends on the client's asset structure, tax residency and chosen booking centre. If you would like help interpreting this for your own situation, you can register your needs through the contact details on this site.