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Risks relating to the RQFII regime
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RQFII A-share ETFs are physical, RMB denominated ETFs investing directly in A-shares. The novelty and untested nature of RQFII potentially makes RQFII A-share ETFs riskier than traditional ETFs investing in markets other than Mainland China. |
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RQFII A-share ETFs will utilize RQFII quota of the relevant RQFII quota holder. In the event that the quota is reached and the RQFII quota holder is unable to acquire additional RQFII quota, creations of new units of the RQFII A-share ETF may be suspended.In such an event there may be significant differences between the trading price of a unit of the RQFII A-share ETF and the net asset value per unit. |
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The RQFII policy and rules are new and there may be uncertainty to its implementation and such policy and rules are subject to change and hence may adversely impact RQFII A-share ETFs. |
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b. |
RMB trading and settlement risk |
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Not all Exchange Participants or Clearing Participants may be ready and able to carry out trading and settlement of RQFII A-share ETF units traded in RMB on the Exchange. |
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The limited availability of RMB outside Mainland China may also affect the liquidity and trading price of the units. |
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Any disruption to the availability of RMB may adversely affect the capability of securities market makers in providing liquidity for the units of the RQFII A-share ETF traded in RMB.
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c. |
Risks relating to Mainland and A-share market |
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Given that the A-share market is considered volatile and unstable (with the risk of suspension of a particular stock or government intervention), the creation and redemption of units of the RQFII A-share ETF may also be disrupted. A Participating Dealer is unlikely to redeem or create units of the RQFII A-share ETF if it considers that A-shares may not be available. |
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Investing in Mainland China-related companies and in the Mainland China markets involve certain risks and special considerations not typically associated with investment in more developed economies or markets, such as greater political, tax, economic, foreign exchange, liquidity, legal and regulatory risk. |
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d. |
Mainland tax risk |
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There are risks and uncertainties associated with the current Mainland China tax laws, regulations and practice in respect of capital gains realised by RQFIIs on its investments in Mainland China (which may have retrospective effect). RQFII A-share ETFs may have made a tax provision in respect of potential Mainland China tax liability. Such provision, however, may be excessive or inadequate to meet final Mainland China tax liabilities. Any shortfall between the provision and actual tax liabilities may be covered by the RQFII A-share ETF’s assets and may adversely affect the ETF’s net asset value (NAV). |
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e. |
RMB currency risk |
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RMB is currently not freely convertible and is subject to exchange controls and restrictions. Since RQFII A-share ETFs are denominated in RMB, non-RMB based investors are therefore exposed to foreign exchange risk as a result of fluctuations in the RMB exchange rate against their base currencies.The exchange rate of RMB may rise or fall.If investors wish or intend to convert the redemption proceeds or dividends paid or sale proceeds (in RMB) into a different currency, they are subject to the relevant foreign exchange risk and may incur substantial capital loss from such conversion. |
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Difference in trading days and trading hours |
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Same as ETFs with overseas underlying, there are differences between the trading days and trading hours of the Mainland China and Hong Kong exchanges. For example, in the case when the Shanghai and Shenzhen exchanges are open and Hong Kong is closed (e.g. due to a public holiday in Hong Kong but not in Mainland China), the value of the securities in the RQFII A-share ETF’s portfolio may change while no trading is conducted in the Hong Kong market and investors will not be able to purchase or sell units of the RQFII A-share ETFs. |
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On the other hand, differences in trading hours between Shanghai and Shenzhen exchanges and Hong Kong may increase the level of premium/discount of the unit price to its NAV since the underlying Mainland markets are closed while Hong Kong is still open (e.g. between 3pm to 4pm). |
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A-shares are subject to trading bands which restrict increases and decreases in the trading price, while securities listed on the Exchange are not. This difference may also increase the level of premium/discount of the unit price to its NAV. |
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g. |
Mainland brokerage risk |
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Manager of an RQFII A-share ETF can only appoint one broker in Mainland China for each market (the Shenzhen Stock Exchange and the Shanghai Stock Exchange) in Mainland China to conduct trading.Hence, an RQFII A-share ETF will rely on only one broker for each market (which may be the same broker). If the manager of the RQFII A-share ETF is unable to use the relevant broker in Mainland China, the operation of the RQFII A-share ETF would be adversely affected and may cause units of the ETF to trade at a premium or discount to the ETF’s NAV or unable to track the underlying index. |
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Government intervention and restriction risk |
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Governments and regulators may intervene in the financial markets, such as by the imposition of trading restrictions which may affect the operation and market making activities of RQFII A-share ETFs. |
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i. |
New ETF manager and reliance on parent company |
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The manager of RQFII A-share ETFs may be inexperienced in managing ETFs and may heavily leverage on the expertise and system of its parent company (sometimes the Investment Adviser of the ETF) to support the ETF’s investments in the A-share market. |
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Any disruption in the support from and communications with the Mainland parent company may adversely affect the operations of the RQFII A-share ETF. |