Overview
- In a formal submission, the Hong Kong Securities & Futures Professionals Association backed CARF’s transparency goals but urged proportionate local implementation.
- The group asked for a six- to twelve-month deeming period so firms can keep operating while new virtual-asset licences for dealers, advisers, custodians and managers are processed.
- Industry stakeholders opposed uncapped per‑account administrative fines, seeking penalty caps and reasonable‑excuse safeguards for unintentional or technical errors.
- They urged that record‑keeping duties after corporate dissolution not fall on former directors, proposing transfers to designated licensed custodians instead.
- Firms requested API-based filing with early XML schemas and a testing sandbox, plus legal clarity under Hong Kong privacy law for wider upfront data collection, as consultations continue toward first CARF data exchanges targeted for 2028.