The Securities and Futures Commission (“SFC”) published the revised Fund Manager Code of Conduct (“FMCC”), which came into effect in November 2018. The revised FMCC introduced a number of significant changes on fund managers’ responsibilities for the overall operation of their funds and discretionary accounts.

Since the introduction of the revised FMCC, we have performed various independent reviews for a range of fund managers and noted a number of deficiencies. Summarised below are the key updates introduced in the revised FMCC and some common deficiencies observed during our reviews.