SFC Issues Guidance on Disclosure and Complex Product Treatment for Funds with Private Market Exposu
The Hong Kong SFC has issued a circular requiring management companies of SFC-authorized public funds with direct or indirect private credit or private equity exposure to adopt enhanced offering document disclosures. Funds with 50% or more of NAV in private market assets will be classified as complex products, and the SFC may also designate funds below that level. Compliance teams should begin reviewing existing funds now, as the SFC expects updates as soon as practicable.

