Completing SIS-1 Supplementary Information for a Company Money Lenders Licence Application

Money Lenders SIS-1 Supplementary Information for Companies

A company's application for a money lenders licence in Hong Kong must include Form 3 and the money lenders SIS-1 supplementary information form. This form requires detailed corporate, financial, and operational information to support the licence application. The specific information required for SIS-1 is outlined below.

SIS-1 Money Lenders Supplementary Information: Purpose and Scope

The SIS-1 form is the supplementary information schedule for a company's money lenders licence application under the Money Lenders Ordinance (Cap. 163). The Licensing Authority, the Commissioner of Police, uses it to assess if the company applicant meets the fit and proper criteria to operate as a licensed money lender. Required supplementary information covers the company's corporate structure, financial position, business plan, and compliance arrangements.

Hong Kong Money Lenders SIS-1: Corporate Structure Requirements

The SIS-1 form requires the company applicant to disclose its full corporate structure. This includes details of any holding company and all subsidiaries within the group. A group structure chart must show the ownership chain from the ultimate beneficial owner to the applicant company. For each entity, the company must state the registered name, place of incorporation, registered address, and percentage of shares held.

Particulars of every director, any shareholder holding 10 per cent or more of the issued shares, and any person exercising significant control are also required. These individuals must provide their full name, Hong Kong identity card number or passport number, residential address, and occupation. The Licensing Authority uses this information to conduct fit and proper checks on all persons connected with the company.

Supplementary Information for Company Application: Financial Statements and Business Plan

The company must submit its audited financial statements for the most recent financial year. If the company has operated for less than one year, it must provide management accounts from the date of incorporation. These statements must show the company's assets, liabilities, income, and expenditure. The Licensing Authority examines them to assess whether the company has sufficient financial resources to operate as a money lender.

A detailed business plan is also required. The plan should describe proposed lending activities, including loan types, target customer base, expected loan volume, and interest rates to be charged. It must also explain the source of funds for lending, detailing any bank facilities, shareholder loans, or other funding arrangements.

SIS-1 Form Money Lender Company: Source of Funds and Financial Projections

The company must disclose the source of funds for its lending operations. A statement must show the origin of all funds to be used for lending, including any loans from directors, shareholders, or financial institutions. If funds come from a related company, the relationship must be explained and supporting documentation provided.

Financial projections for the first three years of operations are also mandatory. These projections should include projected income statements, cash flow statements, and balance sheets. They must be based on reasonable assumptions about loan volumes, interest rates, and operating expenses. The Licensing Authority uses these projections to assess the company's ability to sustain its lending operations without becoming insolvent.

Compliance Programme and Internal Controls

The company must describe its compliance programme and internal controls. It must explain how it will ensure compliance with the Money Lenders Ordinance and other applicable laws. This includes procedures for verifying borrower identity, conducting credit assessments, calculating interest rates within legal limits, and handling loan collections.

The compliance programme must also address anti-money laundering measures. The company must describe its procedures for identifying and reporting suspicious transactions, conducting customer due diligence, and maintaining records. Internal controls should include segregation of duties, approval limits for loans, and regular internal audits.

Group Structure and Related Party Transactions

If the company is part of a group, the SIS-1 form requires details of all related party transactions. The company must disclose any loans, guarantees, or other financial arrangements between the applicant company and its holding company, subsidiaries, or other group entities. The Licensing Authority examines these transactions to ensure they are at arm's length and do not expose the company to undue risk.

A declaration is also required that no person connected with the company has been convicted of any offence under the Money Lenders Ordinance or any other law relating to money lending. This declaration covers directors, shareholders, and any person who exercises control over the company.

Ultimate Beneficial Owner Disclosure

The company must identify its ultimate beneficial owner. This is the individual who ultimately owns or controls the company, whether through direct shareholding or a chain of ownership. The company must provide the name, address, and nationality of the ultimate beneficial owner. If the ultimate beneficial owner is a trust, the company must disclose the trustee and the beneficiaries.

The Licensing Authority requires this information to prevent money lenders from being used for money laundering or other illegal activities. The company must also confirm that the ultimate beneficial owner is not a politically exposed person or subject to any sanctions.

Verification and Supporting Documents

A director or company secretary of the applicant company must sign the SIS-1 form. Certified copies of supporting documents must be attached, including the certificate of incorporation, business registration certificate, and the company's memorandum and articles of association. If the company has changed its name or registered address, the relevant documents from the Companies Registry must be provided.

The Licensing Authority may request additional information or documents after reviewing the SIS-1 form. The company must respond to any such requests within the specified timeframe, or the application may be refused. Processing time for a money lenders licence application varies, and applicants should check the current fees and processing times with the Licensing Authority.