The SFC put out two circulars on Wednesday, September 30, numbered 26EC60 and 26EC61, and both are about the same regime. One sets out how intermediaries should obtain client consent under the Hong Kong Investor Identification Regime for the exchange-traded derivatives market. The other is a roadmap for intermediaries to implement the regime in that market.

Look, the securities market already runs this regime, where each client is tagged to an identifier (a system that works well until a firm has to ask clients for permission to hand over their identity). Derivatives now get the same treatment, and the consent circular is the one that touches clients directly.

The order of the two numbers is the useful part. Consent is 26EC60 and the roadmap is 26EC61, so the SFC filed the permission mechanics before the timetable. A firm cannot report a client's identity it has no consent to report. The client-facing paperwork therefore comes before any systems build.

My read is that compliance heads at derivatives brokers should treat 26EC60 as the long pole. Systems vendors can be told what to build on a schedule. A client base has to answer a letter, and every client who does not answer is an account the firm will have to restrict once the regime applies to derivatives.

The news block carries only the one-line summaries of the two circulars, not their text, so the roadmap's milestone dates sit in 26EC61 itself. Anyone running a derivatives desk at a licensed corporation has two documents to read this week, and the consent one comes first.