No. Licensed corporations and associated entities are required to electronically submit the BRMQ for financial years ending on or after 31 March 2019.
Q1 : Can licensed corporations and associated entities submit the BRMQ in paper form for financial years ending on or after 31 March 2019?
Q2 : How do I access the electronic BRMQ?
The SFC’s new online portal WINGS, which is a common platform for making electronic submissions to the SFC, provides access to the electronic BRMQ.
A video “BRMQ – The BRMQ online form and its functions” which demonstrates how you can access the electronic BRMQ and introduces its functions is available under the “Online Demo” section of WINGS.
Q3 : The electronic BRMQ for licensed corporations is made up of Section A1 to Section A12 and Section B1 to Section B15. Am I required to complete all sections and every question within each section?
When completing the electronic BRMQ form, a licensed corporation will be directed by automated skip logic to the sections applicable to it. When a licensed corporation has ticked the appropriate option boxes under “Section A1 – Business Overview” to indicate the business activities that it has undertaken during the relevant financial year, the “Index” section at the front of the form will show which applicable sections are to be completed.
Automated skip logic will also direct the licensed corporation to questions applicable to it within each relevant section based on its answers to the preceding questions in that section.
Q4 : Given that the electronic BRMQ form automatically skips questions which do not apply based on my previous responses, can I print out a blank BRMQ form showing its full set of questions for general reference even though not all questions are applicable to me?
A PDF version showing the full set of questions is available for download. To download, click “File” on the menu bar of the electronic BRMQ, and then “Download full blank form in PDF”. If you would like view the full set of questions with the skip logic instructions, you may click “File”, then “Download full blank form in PDF with skip logic instructions”.
Q5 : Must a licensed corporation have in place all the internal control measures, policies and procedures set out in the list of answer options provided for questions in the BRMQ in order to meet the standard expected by the SFC?
No. The SFC recognises that different licensed corporations may adopt different control measures, policies and procedures to achieve the internal control objectives for various operational functions and business lines. Therefore, the answer options provided in the BRMQ are neither intended to be, nor should they be construed as, an exhaustive or mandatory list of measures, policies and procedures for a licensed corporation’s internal control systems. A licensed corporation should adopt such policies and procedures as are adequate and appropriate to achieve the related internal control objectives as well as commensurate with the scope and nature of its business and its operating environment.
Q6 : Who is responsible for approving the BRMQ?
The person approving the BRMQ should be a responsible officer, a Manager-in-charge of Overall Management Oversight or a Manager-in-charge of Compliance of a licensed corporation, or an executive officer of an associated entity. The name of the person approving the BRMQ and his/ her capacity should be indicated in the “Front Page” of the BRMQ.
Q7 : How can I merge the responses saved in different files into a single file for submission when staff from different departments have been assigned to complete different sections of the BRMQ?
When more than one staff is completing the BRMQ, licensed corporations and associated entities may use the “Merge File” function to consolidate responses saved in multiple files into one merged file for submission.
To access the “Merge File” function, click “File” on the menu bar of the electronic BRMQ, and then “Merge file”. A video “BRMQ – Merging responses into a single file for submission” which demonstrates how multiple staff can provide input to the BRMQ online form and their responses can be merged for submission is available under the “Online Demo” section of WINGS.
Q8 : Who is allowed to submit the BRMQ to the SFC via the SFC online portal WINGS?
Currently, only a responsible officer of a licensed corporation or an executive officer of an associated entity is allowed to submit the BRMQ to the SFC in WINGS.
A video “BRMQ – Submission of BRMQ in WINGS” which guides you through the BRMQ submission process is available under the “Online Demo” section of WINGS.
Q9 : Are auditors required to express opinion on the BRMQ?
No. Section 3(1)(c) and 3(3)(c) of the Securities and Futures (Accounts and Audit) Rules require licensed corporations and associated entities respectively to prepare the BRMQ. There is no requirement for the BRMQ to be accompanied by an audit opinion.
What should I do if:
(i) I encounter technical difficulties when completing or submitting the BRMQ?
(ii) I become aware that certain information contained in the electronic BRMQ submitted to the SFC is incorrect?
(i) Please call (852) 2207 9333 or e-mail your enquiries to TechEnquiries@wings.sfc.hk for assistance.
(ii) Please contact your responsible case officer in the Intermediaries Supervision Department.
Last update: 29 May 2020