Yes, an RRI may opt to (but is not obliged to) apply the same BCAN to a client under both the HKIDR-S and the HKIDR-DM, provided that the BCAN complies with the requirements set out in the HKEX Information Papers for the HKIDR-S and HKIDR-DM.

RRIs are reminded to insert its CE number as a prefix before the BCAN for placing orders under the HKIDR-DM and for submission of the BCAN-CID Mapping File. The initial three letters of the RRI's CE Number are required to be in uppercase. For details, please refer to paragraphs 43-45 of the HKIDR-DM Consultation Paper.

The requirements under the HKIDR-DM under paragraph 5.6A of the Code of Conduct only apply to “Relevant Regulated Intermediaries”, which means a licensed corporation or a registered institution which:

i. submits (or arranges to submit) for execution an on-exchange order; or

ii. carries out a block trade order,

in connection with: (i) carrying out proprietary trading by a licensed or registered person licensed or registered for Type 1 regulated activity (in relation to stock options) or Type 2 regulated activity (in relation to futures contracts or other options contracts); or (ii) providing derivatives brokerage services for another person in respect of orders placed through an account opened and maintained for that person.

Whether that licensed corporation should tag a BCAN to an order depends on the capacity in which it acts. If a licensed corporation does not engage in any of the above activities (regardless of whether it is licensed for Type 1 or Type 2 or Type 9 or other types of regulated activities), it is not an RRI for the HKIDR-DM purposes and is not required to assign BCAN to itself or other persons, tag BCAN to the relevant orders, or prepare and submit a BCAN-CID Mapping File to HKFE or SEHK, as the case may be.

Paragraph 5.6A(c) of the Code of Conduct (as set out in Appendix C to the Consultation Conclusions) requires an RRI to assign a BCAN to each of its clients, save in the case of an order being placed from a jointly held futures/options trading account where the BCAN should be assigned to the account itself. “Client” is defined under paragraph 5.6A(m) of the Code of Conduct to generally mean the direct client of an RRI, and “direct client” is defined under paragraph 5.6A(b)(viii) as the most immediate client of an RRI which has placed or proposes to place an on-exchange order or block trade order through a futures/options trading account with that RRI. Therefore, the RRI should assign BCANs to each of these account holders (or in the case of jointly held accounts, the accounts) (but not to the order originators) and collect CID of each of these account holders in these three cases.

In respect of BCAN assignment in the case of discretionary account management, please refer to paragraph 31 in the Consultation Paper.

An LC or RI may be licensed or registered for multiple regulated activities. Whether the asset management company should be responsible for assignment of BCANs depends on the capacity in which it handles a futures/options order, i.e. whether or not it is acting in the capacity of an RRI. Please refer to the definition of “relevant licensed or registered person” in paragraph 5.6A(b)(xiv) of the Code of Conduct (as set out in Appendix C to the Consultation Conclusions).

In the case where the asset management company does not open and maintain futures/options trading accounts for its affiliates in relation to its central dealing desk activities, which are wholly incidental to the asset management activities of itself or its affiliates, the asset management company is not an RRI by virtue of its central dealing desk activities under such circumstance and it is not required to assign BCANs to its affiliates.