JPM | FTM | Today’s Research | Europe

Research evidence excerpt

JPM | FTM | Today’s Research | Europe

new Outbound Direct Investment (ODI) regulation, which we previously

discussed (see Global Banks: China investment regulations triggering WM revenue uncertainty) as a risk but with limited

regulatory clarity at present. Based on the discussion, our findings for the UK Asian and Swiss banks are more negative

than expected with regards to: 1) the scope of individuals, with the definition of Chinese Mainland Residents (CMR) wider

than expected and includes anyone who still has a Chinese household registration & stays in China for more than 183 days (vs

our previous expectation of those with a HK ID card as out of scope); 2) the scope of investments, with no relief expected on

FX restrictions which prohibits RMB-converted funds to be used for investment property and insurance investment products -

with HSBC more exposed to any scrutiny on existing insurance assets given its insurance manufacturing business

compared to StanChart with its third-party distribution model, and; 3) existing offshore financial assets which may be in

scope (alongside new funds) and which may require additional administrative filings/disclosure with scrutiny to existing AUM,

although there is an expectation of a materiality threshold and a grandfathering of rules. For UBS and BAER’s HNW/UHNW

businesses, cashed-out proceeds from overseas IPOs or income earned through offshore subsidiaries are likely to be

in scope of the ODI framework where we have more concerns (vs HSBC/StanChart), which we see creating uncertainty

around new flows while existing offshore financial assets i.e. back book AuM being in-scope would create potentially higher

costs of compliance. Overall, this new regime will result in incremental friction to net new money generation, with