United States
Hong KongMoves that need a second paper
Paper 1 is the local regulatory framework paper for representatives in ten of the twelve regulated activity types. A second paper is required to be approved as a responsible officer, and which one depends on the activity.
Knowing which paper a move requires is the difference between planning a year ahead and discovering it in an offer conversation.
As a representative, Paper 1 usually does it
Paper 1 is the local regulatory framework paper for regulated activity types 1 to 12 with two exceptions. Type 3 takes the VTC leveraged foreign exchange papers instead, and type 7 has no such requirement at all.
So moving between most representative roles does not add a paper. Moving up does.
As a responsible officer, it always adds one
| Regulated activity | Papers |
|---|---|
| Types 1, 4 and 8 | Papers 1 and 2 |
| Types 2, 5 and 11 | Papers 1 and 3 |
| Type 7 | Papers 1 and 6 |
| Type 9 | Papers 1 and 4 |
| Type 10 | Papers 1 and 13 |
| Type 6 | No LRP requirement |
| Type 3 | The VTC responsible officer paper |
Corporate finance has no local regulatory framework paper requirement at responsible officer level, though sponsor and Codes on Takeovers work carry their own additional eligibility criteria. Do not read the absence of a paper as an absence of requirements.
Plan the paper before the move
The recency rule means a paper sat too early can be stale by the time you apply, and a paper sat too late holds up the application.
The sweet spot is sitting the second paper once the move is realistic rather than hypothetical, and while you are still inside the industry so the carve-out protects you.
Adding an activity type
If you are already licensed and want to add a type, the SFC's own example is instructive: someone holding Papers 1 and 7 and licensed for type 1 within the past three years is not required to re-take both when applying to additionally carry on type 2.
Being in the industry is what makes lateral moves cheap.
Common questions
Does Paper 1 cover every regulated activity?
As a representative it is the local regulatory framework paper for types 1 to 12 except type 3, and type 7 has no requirement.
Which paper do I need to become a responsible officer?
Paper 1 plus a second, depending on the activity - Papers 1 and 2 for types 1, 4 and 8, Papers 1 and 4 for type 9.
What about type 6?
No local regulatory framework paper requirement at responsible officer level, though sponsor and Takeovers work have their own criteria.
When should I sit the second paper?
Once the move is realistic, and while you are still licensed so the recency carve-out protects you.
Do I re-sit when adding an activity type?
Usually not if you have been licensed within the past three years for a relevant activity.