Hong Kong Banking Report 2023
Hong Kong Banking Report 2023
Hong Kong Banking Report 2023
Seizing Opportunities
Hong Kong Banking Report 2023
kpmg.com/cn
Contents
Introduction 4
Financial performance 5
Overview of Results 6
Virtual Banks 14
Tax Landscape 24
Growth opportunities 33
ESG 34
Virtual Assets 40
Wealth Management 43
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Business Transformation 47
Technology Risk and AI 48
Outsourcing 51
China Data 54
Banking Turmoil 61
Sophisticated Investors 64
Financial Highlights 69
About KPMG 98
Contact us 99
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
4 Hong Kong Banking Report 2023
Introduction
In our annual report we review the financial
performance of banks in Hong Kong in 2022 and look
at some of the key topics and growth areas for the
sector
Welcome to the latest edition of our annual Hong Kong Banking Report, where
we review the financial results of banks in the city in 2022 and share our
thoughts on the outlook for the sector. This report includes key statistics and
our analysis of the performance of banks in 2022, as well as expert insights into
some of the major trends and topics for banks in the year to come.
Paul McSheaffrey As we come out of Covid and the restrictions that were in place in Hong Kong,
Senior Banking Partner, Hong Kong all of us working in the banking sector in Hong Kong are looking to get back to
KPMG China business and seize the opportunities that exist.
Banking performance
The early months of 2022 were dominated by the fifth wave of Covid and the
Hong Kong (SAR) economy shrank by 3.5% in the year. However, the outlook
brightened considerably towards the end of the year as restrictions were eased.
Despite the slowing economy globally and in Hong Kong, banks in the city
performed well in many areas. This was principally due to the interest rate rises
during the year. As we predicted in last year’s Banking Report, rising interest
rates led to higher net interest margins for banks in the city. This fed through to a
significant rise in operating profit during the year.
However, banks in Hong Kong saw a rise in the impaired loan ratio in 2022, due
in part to their exposure to the China property market. In this report we take a
look at how the China real estate issues in loan portfolios developed and consider
what banks should learn from the experience. We also review the performance
of the eight virtual banks in Hong Kong in their second full year of operations, and
note how they are seeking to differentiate themselves in a competitive market.
We also review some of the key growth areas for banks including ESG and
climate risk management, and the growing opportunities in wealth management
services. Business transformation continues to be a hot topic as banks look to
operate more efficiently while improving their service to clients. New technology
can help banks to transform but also comes with possible exposure to new risks.
New regulations and evolving risk also offer challenges and opportunities, and we
look at some of the latest development in areas including operational resilience
and data analytics that will affect banks in the year ahead.
We hope you enjoy the information and insights in this report. Please feel free
to get in touch if you would like to discuss the financial results or the broader
outlook for the Hong Kong banking industry.
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 5
Financial
performance
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
6 Hong Kong Banking Report 2023
Financial performance
Overview
Following seven interest rate rises in 2022, the US Federal Reserve again
Terence Fong raised the Federal Funds Rate by 25 basis points each in February, March and
Partner, Head of Chinese Banks May 2023. In tandem with the Federal Funds Rate increases, the Hong Kong
in Hong Kong Monetary Authority raised the base rate from 0.5 percent to 4.75 percent during
KPMG China 2022, and further increased to 5.5 percent during January to May 2023. We also
observed a sizable increase in the Hong Kong Interbank Offered Rate (HIBOR) in
2022 from 0.26 percent to 4.99 percent2 (for three-month HIBOR). The composite
interest rate, which is a measure of the average cost of funds of banks, increased
by 190 basis points from 0.21 percent in December 2021 to 2.11 percent in
December 2022.
Moving into 2023, uncertainties about the future interest rate pattern remain
high, but the reducing aggregate balance indicates that HIBOR and LIBOR should
converge as banks offer more attractive rates to attract Hong Kong dollar funding.
The Hong Kong (SAR) Government has forecast the city’s economy to grow by
3.5 to 5.5 percent in 2023, after a 3.5 percent contraction in 2022. The consumer
price inflation is forecast to be 2.5 percent in 2023, up from 1.7 percent in 20221.
1
2022 Economic Background and 2023 Prospects, Hong Kong SAR Government, February 2023, p.2, 8 and 9, https://www.
hkeconomy.gov.hk/en/pdf/22q4_ppt.pdf
2
The Hong Kong Association of Banks - HKD Interest Settlement Rates Highlights
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 7
Looking ahead, the performance of the Hong Kong banking sector in 2023 is
likely to be linked closely to the speed and extent of the economic recovery
in Hong Kong and also the growth of the Chinese Mainland economy, and in
particular the health of its real estate and technology, media and telecoms
sectors. While the high interest rate environment could bring an opportunity to
improve profitability, it is imperative for banks to closely monitor and manage the
credit risk of their loan portfolios.
Hong Kong’s eight virtual bank were all active in the market during 2022: please
refer to the section on virtual banks for more details.
In this report, we present an analysis3 of key metrics for the top 10 locally
incorporated licensed banks4 in Hong Kong. While some banks have a dual entity
structure in Hong Kong (eg a branch and an incorporated authorised institution),
we have not combined their results. The analysis is performed on a reporting
entity basis.
2.0%
1.79% 1.77%
1.67% 1.65%
1.5%
1.39%
1.24% 1.23%
1.14% 1.10% 1.05%
1.0%
0.5%
0%
BS
ng
ng
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2022 2021
The average NIM5 across all surveyed licensed banks increased by 24 basis
points compared with 2021, driven by the higher interest environment with a
relatively steeper yield curve and wider credit spread on financial assets. The
total net interest income of all surveyed licensed banks increased by 23.7 percent
from HK$224 billion in 2021 to HK$277 billion in 2022, contributed by a 47.3
3
The analysis is based on financial institutions registered with the Hong Kong Monetary Authority.
4
The top 10 locally incorporated licensed banks mentioned in this article are the 10 banks with highest total assets among all
locally incorporated licensed banks as at 31 December 2022.
5
NIM is either quoted from public announcements of financial statements, or calculated based on annualised net interest income
and interest-bearing assets or total assets, depending on the availability of information.
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
8 Hong Kong Banking Report 2023
percent increase in interest income and partly offset by a 113.5 percent increase
in interest expenses. The average NIM for the top 10 licensed banks in 2022
increased to 1.36 percent from 1.14 percent in 2021. All the top 10 licensed
banks recorded an increase in NIM.
Among the top 10 licensed banks, DBS Bank (Hong Kong) Limited (DBS), Hang
Seng Bank, Limited (Hang Seng) and The Hongkong and Shanghai Banking
Corporation Limited (HSBC) recorded the top three largest NIM in 2022. DBS
also recorded the largest increase of 46 basis points from 1.33 percent in 2021
to 1.79 percent in 2022. For DBS, net interest income also increased due to
the expansion in both the loans and investment securities of the bank by 15.4
percent and 68.3 percent respectively during the year6.
Hang Seng’s NIM improved to 1.77 percent in 2022 from 1.49 percent in 2021.
The increase was largely driven by the 17 basis points increase in deposit
spreads and 11 basis points increase in net-free fund contribution, which resulted
from the bank’s proactive management of its assets and liabilities structure amid
global interest rate hikes7.
The NIM of HSBC increased by 30 basis points from 1.37 percent in 2021 to 1.67
percent in 2022. The increase was mainly attributed to wider customer deposit
spreads and higher reinvestment yields8.
In our view, the higher interest environment is, in general, positive for the banks.
While future US interest rate movements are subject to a host of uncertainties,
there is a view that there will be at most one or two more rate hikes in 2023.
Hong Kong banks, particularly major banks with larger current and savings
account (CASA) balances, have benefited from rising interest rates. However,
one notable feature of 2022 is that as interest rates increased, funds flowed out
of CASA accounts to seek yield. CASA accounts contributed 47.8 percent of total
deposits at the end of 2022 compared to 61.5 percent at the end of 2021. Going
forward, we can expect more competition on pricing for customer deposits.
6
DBS Annual Report 2022, p.6, 8
https://vpr.hkma.gov.hk/statics/assets/doc/100034/ar_22/ar_22_eng.pdf
7
Hang Seng Annual Report 2022, p.37 https://vpr.hkma.gov.hk/statics/assets/doc/100057/ar_22/ar_22_eng.pdf
8
HSBC Annual Report 2022, p.18 https://vpr.hkma.gov.hk/statics/assets/doc/100002/ar_22/ar_22_eng.pdf
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 9
Costs
Cost-to-income ratios
80%
70% 65.55%
60%
53.72%
51.38%
50%
43.50% 44.14%
39.03%
40% 26.77% 36.17%
28.86% 30.40%
30%
20%
10%
0%
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2022 2021
While Hong Kong’s domestic economic activities gradually revived alongside the
generally stable local pandemic situation in the second part of 2022, the increase
in total staff costs of the surveyed banks moderated, with a slight increase of 1.1
percent in 2022 comparing to the 8.1 percent increase in 2021.
The top 10 surveyed banks showed a 13.2 percent increase in total operating
income, combined with a 2.4 percent increase in total operating expenses. The
weighted-average cost-to-income ratio of the top 10 banks improved from 49.5
percent in 2021 to 45.2 percent in 2022.
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
10 Hong Kong Banking Report 2023
Hang Seng increased its cost-to-income ratio from 42.6 percent in 2021 to 43.5
percent in 2022. The increase was mainly attributed to lower total operating
income resulting from a 22.9 percent decrease in net fee and commission
income and 109.9 percent decrease in net income from financial instruments
measured at fair value through profit or loss. The increase in ratio was also
contributed by the 4.6 percent increase in other operating expenses, mainly
related to IT and staff costs10.
SCB recorded the largest decrease in cost-to-income ratio among the top 10
banks – from 74.3 percent in 2021 to 65.6 percent in 2022, however, it remained
the only bank with a cost-to-income ratio exceeding 60 percent. The reduced
cost-to-income ratio was attributed to the 8.1 percent growth in operating
income, partly offset by a notable decrease of 4.7 percent in operating expenses,
which was driven by a sizable decrease in staff costs of 9.7 percent due to the
decrease in redundancy costs11.
HK$ bn
4,000 3,745
3,500
3,000
2,500
2,000
1,656
1,500
1,201
945
1,000
550 460
500 294 280 242 211
0
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2022 2021
9
ICBC (Asia) Annual Report 2022, p.101 https://vpr.hkma.gov.hk/statics/assets/doc/100077/ar_22/ar_22.pdf
10
Hang Seng Annual Report 2022, p.178 https://vpr.hkma.gov.hk/statics/assets/doc/100057/ar_22/ar_22_eng.pdf
11
SCB Annual Report 2022, p.12 https://vpr.hkma.gov.hk/statics/assets/doc/100269/ar_22/ar_22_eng.pdf
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 11
Total loans and advances of all surveyed banks decreased modestly by 0.6
percent to HK$10,052 billion at year end 2022, after seeing growth of 6.6
percent in 2021, reflecting lower loan demand amid the uncertain environment.
Commercial loans, mortgage lending and loans for use outside Hong Kong
continued to make up most of the loans portfolio, representing 89.5 percent of
total loans, a slight increase from 88.7 percent in 2021. Loans for use outside
Hong Kong and commercial loans continue to be the two largest types of loans.
The balance remained relatively flat for all loan products.
HSBC and Bank of China (Hong Kong) Limited (BOC (HK)) continue to lead the
lending market, constituting 49.1 percent of total loans of all surveyed banks as
at 31 December 2022.
Among the top 10 surveyed banks, gross loans and advances decreased by 0.8
percent to HK$8,671 billion, after an increase of 5.7 percent in 2021. Seven out
of the top 10 surveyed banks recorded a reduction in their loan portfolio.
China Construction Bank (Asia) Corporation Limited (CCB (Asia)) experienced the
greatest relative contraction in loan balances, from HK$303 billion to HK$274
billion in 2022. The decrease was mainly driven by the contraction of property
development lending, transport and transport equipment lending, and trade
finance12.
After experiencing loan contraction in 2019, DBS has grown in the last three
years and showed the largest percentage growth in 2022. The gross loans of
DBS increased notably from HK$158 billion in 2019 to HK$280 billion in 2022,
representing a 77.2 percent increment from 2019. The increase was mainly due
to building and construction loan usage in both 2021 and 202213.
HSBC’s gross loans and advances, which cover its Asia Pacific operations,
decreased by 3.3 percent to HK$3,745 billion14. The overall loan balances for
HSBC’s Hong Kong operations remained stable with a decrease in trade finance
and industrial, commercial and financial lending, partly offset by an increase in
residential mortgages. BOC (HK)’s gross loans and advances increased by 3.2
percent to HK$1,656 billion, which was mainly driven by the growth in both
property development lending and residential mortgage loans15.
12
CCB (Asia) Annual Report 2022, p.90 https://vpr.hkma.gov.hk/statics/assets/doc/100015/ar_22/ar_22_eng.pdf
13
DBS Annual Report 2022, p.28 https://vpr.hkma.gov.hk/statics/assets/doc/100034/ar_22/ar_22_eng.pdf
14
HSBC Annual Report and Accounts 2022, p.106 https://vpr.hkma.gov.hk/statics/assets/doc/100002/ar_22/ar_22_eng.pdf
15
BOC Hong Kong (Holdings) Limited Annual Report 2022, p.280 https://vpr.hkma.gov.hk/statics/assets/doc/100072/ar_22/ar_22.pdf
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
12 Hong Kong Banking Report 2023
Credit quality
Impaired loan ratio
3.0%
2.75%
2.53%
2.5% 2.39%
2.0%
1.68%
1.5%
1.19% 1.25%
1.04% 1.07%
1.0%
0.85%
0.53%
0.5%
0%
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2022 2021
Amid the challenging economic environment in 2022 coupled with the fifth wave
of Covid and the China property market downturn, the credit quality of the Hong
Kong banking sector deteriorated moderately. The impaired loan ratio16 for all
surveyed banks increased from 0.85 percent to 1.36 percent and the impaired
loan ratio for the top 10 banks also increased from 0.87 percent to 1.35 percent.
For the top 10 surveyed banks, BOC (HK) and BoCom (HK) recorded the lowest
and highest impaired loan ratio in 2022, respectively. BOC (HK) had the lowest
impaired loan ratio of 0.53 percent in 2022, up from 0.27 percent in 2021. The
impaired loan ratio of BoCom (HK) increased from 0.11 percent in 2021 to 2.75
percent in 2022, being the largest increase among the top 10 surveyed banks
during 2022. The increase was largely driven by the increase in impaired loans in
relation to the property development and investment sector17.
16
Impaired loan ratio is calculated as impaired loans and advances divided by gross loans and advances to customers.
17
BoCom (HK) 2022 Regulatory Disclosure Statement, p.39 https://vpr.hkma.gov.hk/statics/assets/doc/100320/fd_int/
fd_int_1222_eng.pdf
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Hong Kong Banking Report 2023 13
On the retail side, many banks raised their Best Lending Rates three times and
by 62.5 basis points in total from September to December 202218, which imposed
an additional burden on the mortgage payments of borrowers. The aggregate
value of residential mortgage loans in negative equity increased to HK$66,252
million in December 202219 compared with HK$126 million in December 202120.
These cases were mainly related to bank staff housing loans or residential
mortgage loans under the Mortgage Insurance Programme, which generally have
a higher loan-to-value ratio. However, the overall mortgage delinquency ratio
increased from 0.04 percent in 202121 to 0.06 percent in 202222 and the risks
relating to banks’ residential mortgage loans remained slight.
Going forward, the stabilisation of the pandemic in Hong Kong and the
Chinese Mainland should benefit the local economy and improve corporates’
fundamentals. A key issue for banks to consider in 2023 is the extent and speed
to which demand for housing in China returns and how the financial position of
the real estate developers improves.
18
Half-yearly Monetary and Financial Stability Report, March 2023, p.5 https://www.hkma.gov.hk/media/eng/publication-and-
research/quarterly-bulletin/qb202303/E_Half-yearly_202303.pdf
19
Residential mortgage loans in negative equity: End of December 2022
https://www.hkma.gov.hk/eng/news-and-media/press-releases/2023/01/20230131-8/
20
Residential mortgage loans in negative equity: End of December 2021
https://www.hkma.gov.hk/eng/news-and-media/press-releases/2022/01/20220131-9/
21
Residential Mortgage Survey Results for December 2021
https://www.hkma.gov.hk/eng/news-and-media/press-releases/2022/01/20220131-8/
22
Residential Mortgage Survey Results for December 2022
https://www.hkma.gov.hk/eng/news-and-media/press-releases/2023/01/20230131-7/
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14 Hong Kong Banking Report 2023
In 2022, even amid market challenges, virtual banks continued to see growth
in the number of accounts opened, reaching 1.7 million as of October 202225.
However, the growth rate was more muted than in 2021. The total number of
accounts grew 42% from the fourth quarter of 2021 to the third quarter of 2022
(latest available data), as compared to 186% from the fourth quarter of 2020 to
the fourth quarter of 2021.
(100)
(200)
(300)
(400)
(500)
(600)
(700)
(800)
Livi Bank Mox Bank Fusion Bank ZA Bank WeLab Bank Ant Bank Airstar Bank Ping An
OneConnect
Bank
23
South China Morning Post, 16 January 2023, https://www.scmp.com/presented/business/banking-finance/topics/smart-banking-
millennials/article/3206222/traditional-bank-stands-gain-it-embraces-digital-needs-young-millennials-disrupting-industry
24
Hong Kong Monetary Authority 19 April 2022, https://www.hkma.gov.hk/eng/news-and-media/insight/2022/04/20220419/
25
Keynote Address, Hong Kong FinTech Week 2022, https://www.hkma.gov.hk/eng/news-and-media/
speeches/2022/10/20221031-1/
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Hong Kong Banking Report 2023 15
Ping An OneConnect Bank and Airstar Bank had the best performance results
relative to the other virtual banks, as indicated by the largest percentage decrease
in loss before tax compared to 2021 (27% and 18% respectively), while also
reporting the smallest loss before tax in absolute terms. This better performance
was notably driven by their higher net interest margins.
The total combined gross loans offered by the virtual banks increased significantly
from HK$6 billion in December 2021 to HK$16 billion in December 2022, as all
virtual banks deployed more deposits into lending, evidenced by a higher overall
loan-to-deposit ratio of 54% compared to 25% in the previous year.
10,000
9,000
8,000
7,000
6,000
5,000
4,000
3,000
2,000
1,000
-
ZA Bank Mox Bank Fusion Bank Livi Bank WeLab Bank Airstar Bank Ping An Ant Bank
OneConnect
Bank
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
16 Hong Kong Banking Report 2023
Nonetheless, higher loan sizes did not always correlate strongly to higher
profitability during 2022. For instance, Ping An OneConnect Bank increased its
loan-to-deposit ratio by 1 percentage point to 84% and saw a decrease in loss
before tax of 27%, making it the best performer among the virtual banks. In stark
contrast, Fusion Bank increased its loan-to-deposit ratio by 23 percentage points
to 28%, but had an increase in loss before tax of 22%.
To improve profitability and become sustainable, virtual banks will need to factor
in other parameters aligned with their individual cost optimisation strategies.
Except for ZA Bank and Mox Bank, which continued to grow their deposits
substantially and deploy those into lending, the other six virtual banks
experienced much slower, or even negative, growth in deposits in 2022. In some
cases, however, this has been a strategic decision. Virtual banks are aware that
unrestrained growth in deposits may adversely increase their cost of funds, so
some have decided to limit deposits taken and to strike a balance adapted to
their individual risk appetite.
All in all, as the Hong Kong banking landscape becomes ever more competitive,
it is imperative for virtual banks to keep innovating and implement strategies
to attract and retain customers if they are to become profitable. While in the
short run some virtual banks may be able to benefit from parental support, they
ultimately need a credible path to profitability. As such, we maintain our view that
some virtual banks could quietly cease operations or consolidate their operations
over the next few years.
ZA Bank, WeLab Bank, Mox Bank and Ant Bank primarily cater to the mass
retail market through a range of new products and services such as credit
card statement instalment programmes. Meanwhile, Airstar Bank and Ping An
OneConnect Bank aim to capture a slice of the market for lending to small and
medium-sized enterprises (SMEs), particularly those that may find it difficult to
meet traditional lending requirements.
Moreover, ZA Bank, with the ambition of becoming the go-to bank for Web
3.0 crypto start-ups, has recently been pushing into transfers of crypto and fiat
currencies by looking to offer token-to-fiat currency conversions with licensed
exchanges27. ZA Bank has also been forging a path in international transfers. In
partnership with a global technology company, it has become the first virtual bank
in Hong Kong to offer international transfers with no foreign exchange mark-ups
or hidden fees. This service was launched in November 202228.
26
S&P Global Market Intelligence, 27 June 2022, https://www.paob.com.hk/en/sme-lending.html
27
ZA Bank, News Centre, https://bank.za.group/en/content/18ada6a7-38d2-4813-bc69-79b88bb98145
28
ZA Bank, News Centre, https://bank.za.group/en/content/52983457-16bd-4fde-9f08-9c5df2266430
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 17
Fusion Bank, WeLab Bank and ZA Bank obtained the necessary licenses from the
Securities and Futures Commission in 2022 to start offering wealth management
products and services to customers, while Livi Bank followed suit in early 2023.
ZA Bank and Livi Bank were both granted the Insurance Agency License from
the Insurance Authority to enable them to add fee-based insurance products and
services to their range of offerings. More specifically, ZA Bank has collaborated
with a fellow group company to offer health and life insurance products to
customers30, while Livi Bank has leveraged its existing partnerships and network
of shareholders to launch home and travel insurance products31.
While more investment and insurance licenses may be granted to virtual banks
in 2023, they will also need to be wary of offering too many diverse products or
services, which could risk confusing or diluting their brand identity.
To succeed in Hong Kong and turn their losses around, virtual banks will need to
continue to be innovative and responsive to industry changes.
The key to achieving this is through asserting their brand identity and positioning,
whether that would be in the mass retail market, SMEs lending segment or via
new products. It remains crucial for virtual banks to define and communicate their
value proposition to customers clearly in order to pave a path to sustainability.
29
Hong Kong Monetary Authority 19 April 2022, https://www.hkma.gov.hk/eng/news-and-media/insight/2022/04/20220419/
30
ZA Bank, https://insure.za.group/v2/en
31
Livi Bank, Press Release, https://www.livibank.com/pdf/livi%20bank%20launches%20app-based%20Travel%20Now%20
Insurance%20Plan%20that%20provides%20peace-of-mind%20for%20its%20Customers%20as%20they%20look%20to%20
travel%20again.pdf
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18 Hong Kong Banking Report 2023
Financial performance
Background
China’s real estate activities have grown rapidly since the late 1990s, and for
the past ten years has made up approaching 30% of the nation’s GDP. This is
due to the confluence of several aspects, including the government’s aim to
provide housing and employment for its increasingly urbanised citizens, local
governments’ active sale of land as a primary source of income, developers’ easy
access to credit funding, and high investor demand to own Mainland property, all
of which encouraged a very active real estate market.
Debt, including borrowing from banks, was used to fund much of this growth.
Debt was directly borrowed by the developers onshore and off, but also end-
buyers paid sizeable purchase deposits, also funded with mortgage loans from
banks.
What went wrong was that the developers grew very big, very quickly and
started to lose control of the finances. Money borrowed or received through
purchase deposits for a particular project became fungible with other projects.
The problems were further fuelled as a) people bought additional properties often
as speculative investments, also funded by debt, and b) developers increasingly
undertook higher risk projects in second and third tier cities where fundamental
end-use demand did not exist.
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Hong Kong Banking Report 2023 19
So, what had been a sensible way to support economic growth got derailed –
as has happened in so many other countries – because of bad management,
speculation and excessive debt leverage.
Remedial action
The government recognised this problem around three years ago and introduced
its “three red lines” – restrictions on leverage ratio, gearing ratio and cash ratio –
to try to constrain the amount of debt that POEs were able to access. As a result,
many POEs were unable to borrow more, and those that didn’t have the cash to
complete properties started to default.
Over the past year or so, defaulting developers have been engaging with
their creditors, and in the last few months we’ve started to see restructuring
terms being agreed. In theory, the offshore creditors should be included in the
restructuring plans. However, the complexity of the groups, the structure of
offshore borrowings, and the way the restructurings are being organised means
that it is unlikely that offshore creditors will be repaid in full.
Hong Kong banks got into this situation by lending to the offshore holding
companies (holdcos) of the real estate developers, which were based in Hong
Kong, but often incorporated in offshore centres like Cayman, Bermuda, etc.
However, the vast majority of operating businesses and development projects
– sometimes hundreds of them – sat in the Chinese Mainland. Many developer
groups are large and complex, with projects held by numerous individual
subsidiaries, joint ventures or associates. The offshore holdcos are far distant
from the cash-generating assets, with substantial debt owed by the individual
project entities and by multiple priority debt hurdles owed by intermediate holding
companies.
Although there is a strong drive from national and local government to get these
projects completed, the authorities are not going to bailout the developers, nor
the creditors. They will allow the process to be worked through, and it will take
several years for these projects to be completed.
A few restructuring plans have been announced recently, including for the
largest, Evergrande. Some industry analysts have commented that the plans are
not really restructurings, they are more long-term deferments of the debt. In the
case of Evergrande, creditors are offered one alternative of bullet payments out
10 to 12 years, with interest only capitalised.
The reality is that these long-term “rescheduling” plans will provide breathing
space to enable projects to be finished, but are unlikely to be enough to create
value and sufficient cash necessary to repay all the associated debt.
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20 Hong Kong Banking Report 2023
The key lesson for banks from China’s real estate crisis is a reminder of the basic
rules of lending: lend (have direct legal recourse) to the entity that legally owns
the asset, where the cash will be generated to repay the loan. Over the past
few years creditors have let this principle slip, and have accepted the “structural
subordination” that goes with these offshore-onshore loans, putting themselves
in a very difficult position once a company defaults. A decade and half of ultra-low
interest rates, and an insatiable demand by clients to borrow explains this lapse.
Weaknesses of structural subordination were exacerbated by creditors relying on
“refinancing” as their primary source of repayment, a speculative assumption and
one that should rarely be the basis of a credit approval.
The banking sector has seen similar issues before, such as the Mainland
government “window companies” in Hong Kong in the late 1990s and Asian
commodity companies in more recent years. The failure to avoid the same
mistake this time, and more importantly the need to avoid it in the future, is
something bank governance committees should reflect on.
Despite the material sums involved, and the long wait expected before certainty
of loan recoveries will be clear, the China real estate crisis has not been hugely
detrimental the Hong Kong banks involved. Hong Kong banks’ profits may be
dampened by any further need to raise ECL, but banks in Hong Kong are well
capitalized so should comfortably absorb any residual negative impacts.
While the overall impact on Hong Kong banks may not be severe, the China real
estate challenge provides useful reminders to risk governance committees that
can be distilled into three areas:
1. Constantly ask, where is the next bubble? Actively identify material exposures
to potential asset/market bubbles with high concentration and correlation risks
and ensure the related risk appetite is reviewed, approved and effectively
monitored.
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Hong Kong Banking Report 2023 21
Hong Kong
as an IFC
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22 Hong Kong Banking Report 2023
Back to Business
The government is aware of the challenges and has made the financial sector
a key focus of its recovery efforts. One of its first “back in business” activities
was the high-level banking summit hosted by Financial Secretary Paul Chan in
November last year. The government has also rolled out a range of promotions
to attract tourists, business travellers and investors back to the city, which will be
essential for a full economic recovery.
Paul McSheaffrey
Senior Banking Partner, Hong Kong Key advantages
KPMG China Hong Kong’s key advantages as an IFC remain solid. Our location at the heart
of Asia and excellent connectivity are as important as ever, while our low and
simple tax rate remains globally competitive. The city has a superb professional
services ecosystem with world-class talent including lawyers, advisors and
accountants. All of these are underpinned by the strong foundation of the rule
of law, with the benefits of a common law system, independent judiciary, clean
transparency index and trust in the core system.
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Hong Kong Banking Report 2023 23
and the rest of the world. This will involve helping Chinese companies seeking
growth in new markets including Southeast Asia, the Middle East and Central
Asia, as well as international corporates keen to explore the emerging onshore
opportunities.
Hong Kong also benefits from cross-border ties in terms of product innovation.
The Greater Bay Area is at the forefront of innovation in financial products and
fintech, and China has some of the most innovative payment methods in the
world. To date, these have mostly been applied in a closed payment loop, but
Hong Kong could be the channel to test a more regional reach. China is also
moving forward in Central Bank Digital Currencies, with development of the
E-CNY.
Looking ahead, Hong Kong should also look to develop its own product
innovations related to areas where the city is already strong. In ESG, for example,
Hong Kong is doing well in green finance. But we should also see where we can
contribute to the real economy – in energy, recycling, real estate and transport
– and ensure that the financial services sector is helping these industries to
become sustainability leaders.
The government has also been developing the city’s cultural attractions, including
the opening of the M+ gallery and Palace Museum as part of the West Kowloon
Cultural District. These enhancements can have an impact beyond the tourism
and culture sectors.
Hong Kong can offer all of these as part of our many attractions a global city.
Right now, Hong Kong is enjoying an economic rebound driven by the border
reopening and the end of Covid restrictions. This is perhaps a prime opportunity
to spread the word and ensure that we can continue to attract the world-class
talent needed to further strengthen our foundations as an IFC.
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24 Hong Kong Banking Report 2023
Tax Landscape
But even after BEPS is introduced, Hong Kong will continue to offer tax
advantages compared to many other jurisdictions, and banking groups along with
Irene Lee other large corporates will continue to want to do business here.
Partner, Tax, Hong Kong
KPMG China Talent and capital
Talent and capital are key attributes of Hong Kong’s place as an IFC, with tax an
important enabler of both.
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Hong Kong Banking Report 2023 25
The question then arises, how much of the income generated by traders
and relationship managers in Hong Kong should be retained here and how
much shared with the rest of the organisation? A similar question applies for
operations: how are the costs of operations teams based in Hong Kong but
serving regional branches being shared across the group?
The quantum, nature and form of remuneration paid to these individuals then
comes in to play, with the very same attributes that are important to corporates
also important for their employees.
Another key attribute of Hong Kong as a financial hub is the large capital market.
When major banks raise capital, much of it is done centrally then downstreamed
to the banks’ operating subsidiaries. Banks need to identify the right time and
place to raise funding, then figure out how to push the funding out to the group
in the most tax effective and efficient manner. This includes ascertaining how
much the subsidiary should be paying by way of funding costs for that capital
that has been downstreamed.
Hong Kong’s specific tax rules for regulatory capital securities provide a
robust framework for the tax implications for funding raised in Hong Kong or
downstreamed to and through Hong Kong.
Transfer pricing deals with how the income and costs in multinational businesses
are divided up across the group appropriately. It is particularly important because
Hong Kong is both a centre of excellence for senior bankers and a global or
regional headquarters for a lot of banks and other multinational corporates, which
generally provide support to affiliates in other jurisdictions. For example, traders
in Hong Kong will support the generation of significant income and gains off a
global platform. Equally, a bank’s head or regional office in Hong Kong will incur
costs, much of which will be used to support the regional business.
In Hong Kong, transfer pricing guidelines were put in place in 2018. These not
only give clear guidance to banks operating in Hong Kong, but also ensure that
they have the supporting evidence and documentation to demonstrate to tax
authorities in Hong Kong and in other jurisdictions that income and costs are
being recorded properly and in the right place.
Banks should make it a priority to ensure that they are following the transfer
pricing guidelines and that they are being proactive in terms of preparing the
required documentations and collating evidence for record purposes.
The guidelines in Hong Kong do create a compliance burden for banks, as well
as additional costs such as fees for service providers. This cost and compliance
must also be borne in advance of any queries from the tax authorities.
But once they receive audit requests, banks will appreciate the benefits of the
head office in Hong Kong having robust processes. Some other jurisdictions
have very rigorous audit procedures, so it is especially useful to have the transfer
pricing documentation prepared ahead of any questions from the tax authorities.
The guidelines also demonstrate that Hong Kong has a transparent tax
environment and a framework in place to ensure that procedures are being
followed, which is important to our global standing as an IFC.
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26 Hong Kong Banking Report 2023
Another thing that has complicated matters is that Hong Kong has introduced
certain incentives to encourage the development of the financial sector, in areas
including corporate treasury centres, reinsurance, family offices, funds and other
consolidations of wealth. Industry participants that want to take advantage of
these incentives will need to ensure they are ready to tackle a certain amount of
additional complexity and compliance requirements.
But while Hong Kong’s tax system has become more complex in recent years, it
is still very straightforward by global standards as well as having a relatively low
tax rate as compared to most other jurisdictions.
So despite the recent changes, as an IFC, our tax environment remains very
attractive to global and regional corporates and financial institutions.
In terms of Hong Kong as an IFC, it is worth noting that there is also a tax lever
in attracting people to come to the city to work. Compared to other world-class
financial cities, Hong Kong’s income tax is relatively low, which will continue
to be an attractive proposition for talent. Furthermore, Greater Bay Area cities
have been introducing incentives to bring income tax in line with Hong Kong and
to make it more attractive for Hong Kong-based talent to also work across the
border.
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Hong Kong Banking Report 2023 27
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28 Hong Kong Banking Report 2023
The financial sector has been asking for enhancements to people flow and capital
flow between Hong Kong and the Mainland, so it is a positive development to
see that the programme of opening up has resumed now that Covid restrictions
have eased.
The financial sector Enhancing the links across the GBA is a key policy of both the Central and Hong
has been asking for Kong governments, and Chinese banks have an important role to play across
many aspects, including supporting Hong Kong as a financial hub for the nation,
enhancements to people encouraging the development of the city’s technology and innovative industries,
and promoting the construction of major infrastructure projects such as the
flow and capital flow Northern Metropolis.
between Hong Kong and
Looking more globally, Chinese banks in Hong Kong are also increasingly looking
the Mainland, so it is a at overseas opportunities, especially in Southeast Asia. The banks are taking
different approaches to this expansion exercise, with some converting into
positive development to regional headquarters while others are collaborating with local branches. Some
see that the programme Chinese banks are also actively looking at other locations further afield, including
countries in the Middle East and Central Asia that are part of the Belt and Road
of opening up has Initiative.
resumed now that Covid Hong Kong also serves as a training hub for talent for the Chinese banks’
restrictions have eased. overseas operations as part of these plans to expand internationally.
Technology development
Although the Chinese Mainland is well-known for its advanced technology,
especially in customer service and online access, Chinese banks in Hong Kong
have often been seen as old-fashioned and offering relatively limited services.
This is partly because their client base has largely been focused on Chinese
corporates operating in Hong Kong.
However, Chinese banks are also interested in developing the retail market
locally, so a number of them have been making efforts in brand building to
develop a more modern look – including upgrading their physical branches as well
as refreshing their websites – in a bid to improve their customer experience.
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Hong Kong Banking Report 2023 29
Green opportunities
The Hong Kong government has been working hard to make the city a regional
hub for sustainable finance, and the Central government has also ramped up its
promotion of green finance in the last year or so. Both governments are keen to
encourage investment in green technology and green energy, which will need
funding support that banks can provide.
Chinese banks in Hong Kong are now working to build up their green finance
framework and products including green deposits and loans. Internally, they have
also been enhancing their sustainable efforts, such as setting up sub-committees
under the board level to develop ESG frameworks in line with global practice.
In the Mainland, some Chinese banks have been at the forefront of innovation
in green and sustainable financial products, and have already started to launch
various innovative products in this area, such as personal carbon accounts.
Backed by their domestic parent banks, the Hong Kong subsidiaries can leverage
the experience and framework from the parent banks and can build competitive
advantages in the following ways:
However, there may be some challenges for Chinese banks in terms of adopting
their products and services so they are suitable for the Hong Kong market.
One issue for banks and other businesses is uncertainty about what can be
labelled as “green” or “sustainable”. Hong Kong is currently working on a green
taxonomy that will create a clear set of expectations. Chinese banks in Hong
Kong are quite cautious in terms of regulatory requirements, but once the green
taxonomy has been released this will likely give them more confidence to speed
up their development of sustainable products and services.
Talent is an issue that is affecting Chinese banks in Hong Kong, including in the
areas of ESG and IT, although the whole financial sector is facing manpower
challenges in these areas. In sustainability, there is a general shortage of talent in
the market with the relevant expertise.
For IT, although Chinese banks have struggled to find talent in Hong Kong,
they have been able to draw on the high levels of tech talent in the Mainland,
especially in Shenzhen. A number of Chinese banks have built up their
technology capabilities in Shenzhen recently, due to the widespread availability of
skilled staff.
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30 Hong Kong Banking Report 2023
One explanation for the resilience in exports has been a shift in China’s export
structure. This has meant more exports to markets including ASEAN and the
Middle East where economic performance has been more positive, and less
reliance on economies like the US and EU. However, it is likely that exports will
slow down in the second half of 2023 as the cooler global economic environment
will have an impact.
Another headwind could be the Chinese real estate market, which has improved
from the low base of 2022 but the momentum has weakened a bit in recent
months. If it remains weak, this could become an issue, as the real estate market
contributes significantly to China’s overall GDP growth. In addition, external
challenges could weigh on the global economy this year, including geopolitical
tensions such as the ongoing conflict in Ukraine.
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 31
8,000
6,000
4,000
2,000
-
2015 2016 2017 2018 2019 2020 2021 2022 2023
Hong Kong’s economic prospects are also tied to its role as a key financial centre
for the Mainland. As Hong Kong is an important investment and trade conduit for
business going in and out of China, it will benefit from the economic recovery in
the Mainland in the year ahead.
The Central Government has made clear that it will continue to support Hong
Kong’s role as an international financial centre as well as a financial hub for
the nation. This commitment was reiterated in the report of the 20th National
Congress of the Communist Party of China in October last year.
In practical terms, evidence of this support for Hong Kong’s financial sector
can be seen in the continuing enhancements to the cross-border investment
schemes. In May this year, the interest rate Swap Connect scheme was
launched, adding to the Stock, Bond and Wealth Management Connect schemes
that have been launched since 2014 to deepen the connections between the
Mainland and Hong Kong financial markets.
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32 Hong Kong Banking Report 2023
RMB internationalisation
An important part of Hong Kong’s role as the financial hub for the nation is
in RMB internationalisation. Hong Kong is the world’s largest offshore RMB
business hub, accounting for 73% of RMB international payment transactions.
As the RMB is expected to play a bigger role in China’s trade and finance in the
future, this will provide further opportunities for the development and growth of
Hong Kong’s financial sector.
There has been significant growth in the use of the RMB in recent years,
especially in global trade. According to the Standard Chartered Renminbi
Globalisation Index, international use of the RMB grew by 26% during 202232.
This trend seems likely to continue. For example, in February, central banks in
China and Brazil signed a memorandum to establish RMB clearing mechanism
in Brazil, which should boost the usage of RMB in cross-border transactions
between the two countries. As China is the largest exporter globally, it is aiming
to leverage this leading position to encourage more trade settlement in RMB
terms.
However, it is worth noting that currently the top priority of the Central
Government is to balance economic growth with enhancing national security. The
banking sector in Hong Kong would welcome more clarity and a roadmap on the
development of RMB internationalisation in financial services, which would also
give global investors more confidence about investing in Hong Kong.
32
https://research.sc.com/rgi-dashboard/
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Hong Kong Banking Report 2023 33
Growth
opportunities
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34 Hong Kong Banking Report 2023
Growth opportunities
ESG
In a related move, banks have also been taking steps to acquaint clients with
green and sustainable finance products to help them reduce their own carbon
emissions.
With many clients in the real economy only starting to understand their climate
and transition related risks, the availability of complete, accurate and reliable
information is a concern for many banks. Greenwashing risks and regulatory
and public scrutiny often deter banks from taking more progressive action. The
HKEX’s proposals to mandate climate related disclosures aligned with ISSB
standards33 by 2025 is a welcome development. This will not only pave a path
to greater transparency, reliability and comparability globally, but also greater
accountability. For banks, this means accountability in their role as agents for
change for their stakeholders, including real economy clients.
Within this role, there are three priorities where the banking sector should take
a lead: proactive client engagement, collaboration and partnerships with service
providers, and becoming a guardian of data.
33
The International Sustainability Standards Board (ISSB) Climate Standards that builds on the principles of the Task Force on
Climate related Financial Disclosures (TCFD) recommendations and sets out detailed climate disclosures
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 35
The transition to ESG is creating opportunities for banks, but there are also
hurdles. Most banks acknowledge the role they can play in directing finance to
projects that deliver a positive environmental or social outcome and help their
clients transition to sustainability. However, when it comes to engagement with
clients, client-facing staff often do not feel equipped to proactively initiate this
contact.
A good way for client-facing staff to engage with their clients is by providing
insight on sector trends and how their clients are performing compared with their
peers. A good source for this information may be within the bank’s own transition
plan, which will include sector-specific carbon reduction goals and granular
sectoral transition plans; as well as transition plans of their clients.
Service providers are managed from the perspective of third party risk and
compliance with regulations. When it comes to addressing pressing economic,
social and environmental pressures that affect businesses globally, this approach
excludes them as potential candidates for collaboration.
But what if service provider relationships were not managed as a risk, but
engaged with as a business proposition? This could open up new collaboration
opportunities and a mutually beneficial relationship. Some questions that banks
can ask include:
34
Bain & Company identifies “pioneer strategy” that could deliver profit growth of 25-30% for banks that accelerate transition to
net-zero carbon emissions by 2050 | Bain & Company
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36 Hong Kong Banking Report 2023
• Network – which service providers could enable the bank to grow its formal
and informal networks and scale the delivery of sustainable finance solutions?
For instance, which service providers have access to industry associations or
government departments, or otherwise have influence within their sector?
Critically, to get more value out of relationships with service providers, a starting
point is to see them as potential candidate partners with whom banks have
a shared goal on sustainability, and a shared intent to co-create solutions for
pressing ESG problems.
Banks are faced with a number of ESG data challenges. The issues include
whether the data that is currently available is sufficient to fulfil disclosure needs,
not only in relation to support the basis for disclosures made, but also in relation
to Scope 3 emissions and scenario analysis. More scrutiny is expected on
whether data sourced is accurate, credible and at the level of granularity needed.
There are also questions about the consistency, transparency and auditability of
the data based on which decisions are made.
Where there are known gaps and limitations in data, banks should proactively
manage expectations of both internal as well as external stakeholders. They
should be transparent about data limitations and/or uncertainties associated
with the data and the potential impact these limitations could have, and should
communicate the consequences clearly.
From a data governance and data management perspective, banks should ensure
ESG-related data is handled appropriately, in compliance with relevant laws and
regulations, and commensurate with the levels of risk associated with the data,
and monitored with the same rigor as conventional financial data. They should
also review if the data quality standards and control measures are adequate; and
continuously review and update processes and standards in line with the latest
regulatory requirements.
Banks should also review and make sure that they fully understand their data
sourcing and data ingestion methodologies and traceability measures. This will
provide guidance in identifying required KPIs and metrics. It will also enable them
to evaluate ESG policies and management systems, and deploy more advanced
analytics to support the generation of better quality insights.
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Hong Kong Banking Report 2023 37
Growth opportunities
However, there are pockets of resistance throughout the region where climate
risk mitigation has been put on the back burner as some economies deal with
the post-pandemic recovery by pursuing resource-heavy economic growth. Banks
are presented with the challenge of balancing risk appetite frameworks between
prioritising growth versus climate resilience.
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38 Hong Kong Banking Report 2023
As before, the stress testing includes variables directly related to climate change,
like physical risk from rising sea levels and transition risk such as carbon prices.
A new addition is that economic changes have been embedded. Banks will now
have to merge their traditional macroeconomic variable-driven stress testing with
the new climate change-related stress testing. This will not be a simple A+B
exercise, and banks will need to build new models to merge these two different
stress tests.
This is part of a general trend as central banks around the world are enhancing
their scenarios to integrate variables from both the macroeconomic environment
and climate change.
Banks should ensure that they understand the HKMA’s framework and consider
building -- if they haven’t done so yet -- comprehensive approaches to assess
the risk factors and metrics. These reporting standards are very specific, so a
superficial assessment will not be sufficient.
The challenge for banks will be ensuring that they have the data systems and
modelling capabilities to fulfil these enhanced requirements. Due to regulatory
action and support over the past three years, some local banks have conducted a
lot of work on climate risk, so are generally well prepared to move forward to the
next level.
Regulators from non-banking financial sectors may also consider leveraging the
HKMA platform to develop their own versions. The various financial regulators
in Hong Kong work closely together as part of the same cross-agency working
group to promote sustainable finance and collaborate on green initiatives that
benefit the whole sector.
The new platform is also a significant development for Hong Kong, as HKMA
is the first regulator globally to introduce such an initiative. It sends a positive
signal about Hong Kong’s capabilities in climate risk, and shows that the city is a
proactive leader in green and sustainable finance.
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Hong Kong Banking Report 2023 39
In the future, banks in Hong Kong will also be able to draw on a green taxonomy.
The HKMA, like many other jurisdictions, is working to develop its own set of
standards. Once these are established, this will enable banks to classify their
portfolios in terms of sustainability, and to identify which potential investments
will trigger larger transition risk.
This taxonomy will create considerable financial reporting related impacts, but will
also help banks to further demonstrate how they are managing their climate risk
and their sustainability credentials.
If banks can demonstrate that they are managing their risks well and that they
have developed excellent climate risk management capabilities internally, this
will give them greater bargaining power to win more business opportunities.
They can also use their expertise to develop new products such as green loans,
green bonds, and other green investment products, which are a growing area of
interest among investors.
Banks in Hong Kong have generally made excellent progress in the past few
years on climate risk. In addition to the climate risk stress testing, they have also
had to fulfil other requirements, such as the submissions for the Task Force on
Climate-related Financial Disclosures by mid-2023.
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40 Hong Kong Banking Report 2023
Growth opportunities
Virtual Assets
However, there is no doubt that the collapse Silvergate Bank and Signature Bank
was a significant blow for the industry. One of the key services they provided
was crypto on- and off-ramps – turning virtual assets into fiat money, and vice
versa.
There is now a concern that if the major on- and off-ramps are closed and there
are fewer providers, the costs of on- and off-ramps will continue to rise. There is
also a risk that investors could get shut out from their investments if it becomes
too difficult to exchange fiat and crypto.
Robert Zhan
Cryptocurrency recovery
Director, Risk Consulting, Hong Kong
KPMG China Although the industry has seen a lot of turmoil in the past year -- including
the collapse of crypto exchange FTX and stablecoin Luna in 2022, and the US
Securities and Exchange Commission suing Coinbase and Binance in June 2023 –
in certain aspects it has bounced back recently.
Some of the biggest cryptocurrencies have seen their values recover in 2023
after plunging last year. Ethereum has reached US$2,000, having dipped to below
US$900 in 2022. Meanwhile, Bitcoin reached US$30,000 in mid-April for the first
time since June last year, although it dropped back slightly to around US$26,000
by early June.
Jordan Sanders
Associate Director, Deal Strategy,
Hong Kong
KPMG China
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Hong Kong Banking Report 2023 41
There are a number of reasons why this is happening. There is a theory among
some crypto investors that Bitcoin acts like hard money such as gold, in contrast
to fiat currencies -- especially the US dollar where there are concerns about the
US debt ceiling and printing money.
The demise of Credit Suisse and a number of US banks has also played a role in
the revival of crypto, as it plays into a broader lack of trust in institutions among
some investors, which was one of the key drivers of interest in cryptocurrencies
in the first place.
Hong Kong is among the jurisdictions that has moved towards more regulation,
including a new licencing regime for centralised virtual asset trading platforms
that trade non-security tokens, which came into effect on 1 June. The
introduction of more regulations in Hong Kong and some other jurisdictions are
providing more stability to a market that had previously been seen as not having
much certainty.
The VATP regime has so far attracted companies from both the start-up and more
traditional finance realms, in addition to the exchanges already based in the city.
What remains to be seen is how many of these applications will be approved by
the SFC, which will prioritise maintaining Hong Kong’s reputation as a stable and
reputable financial centre.
Besides crypto exchanges, other virtual assets businesses that have moved to
Hong Kong recently include some that are interested in developing blockchain
applications across the whole virtual assets ecosystem. Another benefit of Hong
Kong being a well-regulated location for virtual assets is that global investors
interested in the sector are likely to want to deploy their capital in a more stable
jurisdiction.
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42 Hong Kong Banking Report 2023
Another good sign for the sector is that virtual asset companies in Hong Kong
are continuing to attract investment. Start-ups that provide a link between digital
assets and traditional finance are among those that have been successful in
getting funding recently. One example is a platform that allows users to stake
NFTs, which can then be collateralised against US dollars, Hong Kong dollars or
cryptocurrencies. Another area attracting attention is payments, such as start-
ups that are working with traditional credit cards to enable the use of digital
currencies.
In contrast, virtual asset firms operating purely in the defi space are not getting
as much traction at the minute.
Besides its efforts on the regulatory side, the Hong Kong government has been
active in the market. Government officials including Financial Secretary Paul
Chan, as well as senior executives from the SFC and HKMA, have spoken at
industry events across the region about their plans to support Hong Kong as a
hub for virtual assets.
However, major banks are not ignoring the sector and many are using blockchain
technology as part of their internal processes and in areas including trade
finance solutions. For example, a number of major banks have been working
with a cross-border payments network that uses blockchain technology. Broadly
speaking, banks in Hong Kong are making sure that they understand the
technology and that they will be in a position to adopt it in the future.
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Hong Kong Banking Report 2023 43
Growth opportunities
Wealth Management
Over recent decades, there has been a significant level of emerging wealth in
Asia, particularly in China, that was created by first-generation entrepreneurs
and business owners. That wealth is now being passed down to the second and
third generations. At the same time, the Chinese Mainland’s GDP has grown
Chee Hoong Tong significantly creating new first-generation wealth. All of this is creating more
Partner, Asset Management, Hong Kong opportunities for the wealth management sector.
KPMG China
Mainland China market outlook
Given these developments, many Hong Kong banks have focused on the China
market. Traditionally, this has been through the offshore model, where the bank
and booking centre for the wealth management business is based in Hong
Kong. The bank targets onshore clients who have capital assets in Hong Kong,
and provides them with investment advice, access to a broad range of products
Leon Ong and, for ultra-high-net-worth (UHNW) clients, access to estate planning and trust
Partner, Financial Services services.
KPMG Singapore
The potential of China’s wealth management sector is being shaped to a certain
extent by policy developments. At the 20th Party Congress held in October last
year, a number of themes emerged, including:
Another driver for wealth management is the shift away from traditional forms
of investing. Historically, people in China have saved cash, invested in risky
products or put their money in property. Real estate investment is likely to have
a diminished role going forwards, partly because of the fall in values but also
due to the China government’s policy that “Property is for living in and not for
speculation”.
To play a part in the growing China market, foreign banks have been positioning
themselves in two ways. One is the offshore model, as described above where
the client’s account may be booked in Hong Kong or Singapore, and another is
the onshore model: over the last decade, a number of multinational banks have
established securities entities and locally incorporated banks onshore so they
can deliver private wealth management services in China. This has been a long
process, and also a learning process for many of them, given that domestic
wealth managers have much a larger customer base, distribution strength and
a deeper understanding of onshore clients’ needs. However, this long-term plan
has started to pay off and foreign banks are now seeing more interest in their
products and services.
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Hong Kong Banking Report 2023 45
Furthermore, the reopening of the border in early 2023 has been a very positive
development. The long period of travel restrictions created significant pent-up
demand, and now clients from the Chinese Mainland can come to Hong Kong to
open accounts and explore other wealth management services.
The Hong Kong government has also introduced a number of policy incentives.
These include the new family office tax regime, which provides a profits tax
exemption for qualifying transactions in Hong Kong and encourages UHNW
families to set up a family office in the city. These clients tend to have complex
requirements including assets in multiple jurisdictions, succession planning and
insurance needs.
Another incentive, announced in this year’s Budget, are changes to the Capital
Investment Entrant Scheme. This scheme allows individuals to gain residency
in Hong Kong if they invest a certain amount in local assets, including equities
listed in Hong Kong. Such programmes should attract more capital to Hong Kong,
which will in turn drive the demand for wealth management services.
Private banks that plan to meet the demand of new family offices setting up in
Hong Kong will need to ensure that they can provide the breadth of services that
UHNW families will need in addition to wealth advisory capabilities including trust
services and succession planning, wealth preservation and insurance solutions,
access to a network of tax and legal advisors, and for selected clients the ability
to meet their ESG related and philanthropic needs.
Virtual assets will continue to be an interesting area, especially as Hong Kong has
introduced more regulatory clarity, including licensing requirements to operate
a virtual assets trading platform and clear rules around the sales and suitability
obligations for wealth managers if they plan to provide their clients with access
to virtual assets. It is early days for these types of assets in the private wealth
management sector, but potentially an emerging trend over the next few years.
Private wealth managers should gauge their clients’ appetite for virtual assets,
particularly UHNW clients who may be trading on virtual asset exchanges directly
or gaining access via hedge fund investments, and explore building linkages with
licensed exchanges in Hong Kong and updating suitability rules and portfolio
advisory tools to accommodate this emerging asset class.
Over recent years wealth managers in Hong Kong have invested heavily in digital
propositions. These have developed from simple propositions such as giving
clients the ability to buy and sell equities and other products to providing clients
with educational content, research and actionable investment ideas. Banks have
also invested in AI to better understand clients’ needs and interests, which is
also giving relationship managers more information to enable them to have more
insightful discussions with clients. Looking to the future, private wealth managers
should start exploring the use cases for large language models and generative AI
across the bank, whilst being mindful of the risks of this emerging technology, as
it is likely to have a significant impact on client servicing, market and data analysis
and risk management.
35
KPMG PWMA Hong Kong Private Wealth Management Report 2022
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46 Hong Kong Banking Report 2023
While the Chinese Mainland will likely remain the key driver of Hong Kong’s
wealth management sector, the emerging wealth across the rest of Asia is
also creating a growing middle class is providing a further and growing market.
Associated with this segment is the growth of the robo-advisory landscape
across Asia, which while still small in absolute terms has been growing steadily.
Private wealth managers, particularly those with an affiliated asset management
business, should assess if robo-advisory tools can be deployed to provide a lower
cost distribution channel in developing markets.
Another theme that will impact the wealth market is the shifting demographics
in the Chinese Mainland and across the rest of Asia as wealth passes
down to the second and third generations. These younger generations have
different requirements, especially when it comes to ESG and sustainable
investing. Currently, there is a scarcity of products in this space to meet the
rising interest, so there is an opportunity for Hong Kong wealth managers to
differentiate themselves in terms of offering a range of ESG and sustainability
products. Private wealth managers should seek to understand their clients’ ESG
perspectives, priorities and needs during client onboarding or during periodic
portfolio reviews, have a robust product due diligence process supported by
appropriate data feeds, and develop reporting tools and dashboards that allow
customers to track the impact of their investment in terms of their specific ESG
priorities.
Wealth managers in Hong Kong will also need to manage ongoing challenges.
For example, there is pressure to increase efficiency and manage costs while
also pursuing growth opportunities and increased revenue to maintain, and ideally
reduce, the bank’s cost-income-ratio. Additionally, scarcity of talent is likely to
remain an issue for the foreseeable future as banks compete for experienced
relationship managers and individuals with product and regulatory expertise.
Private wealth managers will therefore need to continually look for opportunities
to reduce variable and fixed costs, for example by consolidating support activities
and infrastructure across booking centres and at the same time build an operating
model, products and services suite. They should also create a corporate culture
that will develop, attract and retain the best relationship managers and client-
facing staff.
The next couple of years will be exciting times for the Hong Kong wealth
management sector as competition intensifies, further opportunities in the
Chinese Mainland emerge, new technologies become available, and wealth
providers navigate the challenges and risks associated with operating in the
sector.
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Hong Kong Banking Report 2023 47
Business
Transformation
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48 Hong Kong Banking Report 2023
Business Transformation
Banks in Hong Kong have already been using AI in their customer service
chatbots. The more advanced AI that is emerging means that the chatbots will
be able to answer more complicated questions and provide more precise and
detailed answers. Banks in the United States and some other jurisdictions have
already been using AI in various areas, and it has been estimated that this can
reduce operational costs by as much as 40%.
Managing risk
With generative AI, from the technology risk perspective, one of the hot topics is
the integration of responsible AI practices into AI adoption as new use cases are
adopted.
For example, data privacy issues could arise in the conversations between
customers and chatbots. The question is whether, and to what extent, these
conversations will be used to train the AI models, and what that means for
the customer’s data privacy. More generally, banks must consider the risk
implications as they increasingly incorporate AI in areas including customer
communication and data analytics, as well as streamlining and automating their
manual processes.
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Hong Kong Banking Report 2023 49
To use AI effectively while protecting against risk there are some key areas banks
should be focusing on: data quality, transparency, compliance, cybersecurity and
governance.
• Data quality: Banks need to ensure that the AI data is reliable. AI systems
are only as good as the data they are trained on, and poor quality data can
lead to inaccurate predictions, which can have serious consequences.
The regulators and government in Hong Kong have been keeping track of
technology developments and the risks involved, and have provided guidance to
banks and other businesses.
The Office of the Government Chief Information Officer (OGCIO), Hong Kong
SAR Government, has also released the Ethical Artificial Intelligence Framework,
to provide guidance to businesses and sectors on key areas to consider when
organising AI projects. These areas include, for example, privacy, safety and
accountability, among others.
For banks, the HKMA issued a circular, titled High-level Principles on Artificial
Intelligence, in 2019. The circular provides an overview of the key concerns
around the use of AI and proposed solutions. These include areas such as board
and senior management oversight on the AI applications, the required expertise,
periodic reviews and ongoing monitoring, and contingency plans in case of any
identified issues.
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50 Hong Kong Banking Report 2023
A new use case example is AI can identify unusual patterns in transactions that
may be suspicious when reviewing fund transfers. Currently, AML involves
a lot of manual handling and time spent dealing with exceptions. Reducing
these exceptions through AI adoption, instead of pre-defined rule-sets, will help
productivity and increase efficiency.
It is highly likely that AI and other emerging technologies will become even more
important to banks across a variety of areas of operation in the next few years.
Banks should be preparing now to ensure that they have the risk frameworks
in place, as well as the right talent to support them as AI becomes even more
critical to banking operations and services.
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Hong Kong Banking Report 2023 51
Business Transformation
Outsourcing
At the same time, post-pandemic economic growth has been muted, while costs
have remained high, so there is a clear incentive to find more efficient ways
of working. Such pressure on banks’ budgets ultimately reduces their ability to
invest and innovate and could affect competitiveness over the longer term.
Outsourcing can save costs and improve efficiency and accelerate change, while
also freeing up organisational talent to focus on the most important aspects of a
Rupert Chamberlain business. A recent KPMG report that surveyed hundreds of executives globally
Partner, Head of Managed Services, across a range of sectors found that 75% of organisations planned to increase
KPMG China spending on managed services in the next two years.
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52 Hong Kong Banking Report 2023
Complex areas
Besides the more obvious ‘traditional’ areas for outsourcing such as IT Services,
there is now growing appreciation in the banking sector that many other
areas that were previously kept in-house can also be outsourced. These range
from payroll, HR and tax compliance -- including monthly returns, third-party
risk management, regulatory returns and tax computations – to more directly
regulated areas such as KYC and AML, and areas where having leading edge
technology is increasingly important such as fraud risk monitoring.
75%
Proportion of organisations that plan to increase
spending on managed services in the next two
years, according to the KPMG report, Managed
services: A new value proposition
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Hong Kong Banking Report 2023 53
Besides deciding what areas to outsource, banks will also need to consider the
different types of firms in the market, and consider which best suits their needs
for particular projects. These include niche providers that focus on a particular
specialism, as well as larger firms that offer a more holistic approach and can
form a broader relationship with the bank across different business areas.
Measuring success
Once an outsourcing programme is up and running, there are different ways
that banks can measure its success. Cost savings are the most obvious metric.
But perhaps even more important is on the regulatory side. Managed advisory
services enable banks to meet the changing regulatory requirements in all the
jurisdictions where they operate where they may not have the business scale to
cover the cost of compliance.
Customer satisfaction is another area that can be measured, and banks will be
able to assess whether the changes that have been put in place through an
outsourcing project have improved the experience of dealing with the bank for
customers and vendors.
Talent is another crucial area where using advisory managed services can have a
significant impact by offering a solution to the manpower shortage that has been
a long-running problem not just for banks but also for many other sectors in Hong
Kong. External service providers will have not only the technology and know-
how in their particular area, but also the specialised and trained staff to more
effectively carry out the work.
Besides the many benefits for the banks in terms of reducing pressures related
to manpower shortages, the results of a successful outsourcing programme also
has the additional advantage of improving employee satisfaction with their job
and working environment.
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54 Hong Kong Banking Report 2023
Business Transformation
China Data
Under these measures, banks and other businesses involved in cross-border data
transfer will need to:
They can either apply to CAC for approval if the threshold for the Security
Assessment of Cross-Border Data Transfer is met, or file the signed Standard
Contract and other relevant materials at CAC. The threshold includes businesses
that transfer personal information (eg phone number or email address) of more
than 100,000 individuals, or sensitive personal information (eg bank details or
health records) of more than 10,000 individuals, since 1 January of the previous
year.
Kevin Zhou
Director, Technology Risk, Shanghai
KPMG China
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Hong Kong Banking Report 2023 55
The first step for banks that meet the threshold is to carry out a self-assessment,
and make their submission to the CAC. As part of their application, banks need to
explain why they need to transfer data out of the country. For global banks, the
intrinsic nature of their business means that they are interconnected, and cross-
border data transfer is essential for areas like AML and KYC. But the size and
global nature of banks also mean that there are a wide range of potential cross-
border data transfer scenarios that need to be covered, adding further complexity
to their filings.
The deadline for applying for approval from CAC was in March 2023. Therefore,
banks and businesses have already made their submissions and are now awaiting
approval or other comments from the regulator.
Financial institutions must also undergo an additional step as part of the process,
as the CAC needs to consult the National Administration of Financial Regulation
(NAFR) before issuing approval. The NAFR is a new regulator that has replaced
the China Banking and Insurance Regulatory Commission as part of the Central
Government’s recent changes to a number of regulatory bodies.
The CAC is currently working through the applications, and in some cases,
it has given feedback to applicants and asked for further information and
documentation. This means that banks have the opportunity to take remedial
action and consult third-party experts to help fine-tune their applications.
It is possible that the regulator will grant conditional approval to some banks on
the proviso that further conditions are met, such as remediating certain data-
transfer scenarios. Once these conditions have been met, then approval will likely
be granted.
While the new laws have introduced a significant change to how businesses
operate in China with new compliance demands, banks may be in a better
position than businesses from many other sectors. Financial institutions are
very well regulated globally, so banks are generally accustomed to dealing with
regulatory requirements. In addition, overseas banks with a presence in the
Chinese Mainland will also be familiar with Chinese processes and expectations.
Companies from other sectors, such as hotels, retailers and taxi-hailing firms,
that are also affected by the new cross-border data transfer rules, may find the
process more difficult as it is a new experience for them.
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56 Hong Kong Banking Report 2023
Standard Contract
The Standard Contract applies to businesses that do not meet the threshold for
the Cross-Border Data Transfer self-assessment for filing to the CAC, so it will
likely affect some smaller and mid-sized foreign banks operating in China. It is
also notable that the Standard Contract applies to cross-border data transfer of
personal information, and when banks are submitting such contract to CAC, a
Personal Information Protection Impact Assessment report is also required to be
submitted.
Under this requirement, affected businesses will need to revise their data export
processes in line with the regulator’s expectations, and will also need to have a
Standard Contract signed between their China local entity and the global group,
which is the offshore data receiver. The deadline was on 1 June 2023, but there
is also a six-month grace period to give businesses time to ensure they are in
compliance with the measures.
The Standard Contract has many similarities to the GDPR in the EU, which global
banks will already be familiar with. However, it also has some differences in
terms of the scope and filing obligations. One of the key requirements is that
it requires all entities to have the overseas recipient of data sign the Standard
Contract. For foreign branches, this could be their regional headquarters. The
Standard Contract is in Chinese, and as it is a government document, it cannot be
modified, such as being translated, before being signed.
So the offshore signatories may need some assistance from external parties
to ensure they fully understand the Standard Contract and how it affects their
business before signing.
Going forward
Although the Cross-Border Data Transfer requirements and the Standard Contract
are Chinese laws that must be filed in the Mainland, a lot of the stakeholders are
based in Hong Kong, ASPAC or other jurisdictions. As these are key laws for all
businesses that have operations in China, it is important that Hong Kong-based
executives also have a good understanding of the developments in cybersecurity
and data transfer.
Due to the importance of the topic, there is a lot of demand in the market for
guidance to ensure that the approval processes are carried out correctly. The
cost of compliance with the changing requirements is also a consideration. Some
foreign banks have sought assistance from third party firms to get more insight
on what they need to do to follow the requirements in an efficient and cost-
effective manner.
With any new law there will be new challenges to navigate, and it is expected
that the cybersecurity landscape in China will continue to evolve. Going forward,
banks should continue to upgrade their procedures and toolkits to comply with
the current requirements, and stay alert for further guidance from the regulator
that may be announced in the future.
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Hong Kong Banking Report 2023 57
Risk and
Regulatory
Trends
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58 Hong Kong Banking Report 2023
Operational Resilience
One of the vulnerabilities that the regulator is specifically looking at under OR-2
is risks carried by third parties. Banks are being asked to first of all identify where
they are relying on critical third parties, and ensure that they know their vendors
and the processes involved, so that using third parties is not a case of “out of
sight, out of mind”.
Lanis Lam As part of their operational resilience preparations, banks need to select a range
Partner, Technology Risk, Hong Kong of “severe but plausible” scenarios that could cause disruption to their critical
KPMG China operations, including scenarios related to disruptions at a third party or within the
third party’s supply chain. Banks will need to model the impact if a third party
cannot provide the expected service and how long it will take to recover.
For example, if a bank is relying on one third party for a particular service, it could
back this up by using a second service provider. The same with location: banks
should consider having their service centres based in two or more locations to
split the risk if one centre is disrupted. Using multiple service centres means that
even if one centre is shut down, the others in the region can work together to
provide full coverage.
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Hong Kong Banking Report 2023 59
including an annual With their oversight of the entire sector, regulators will also be able to compare
parameters across the industry and may have further insights to share. For
exercise to challenge example, outsourcing could present a concentration risk. Looking at the whole
their operational market, the regulator may find that a number of banks are using the same
material third parties to provide the same service to customers. This would
resilience framework. have a significant impact on the whole Hong Kong banking service capability or
They will also need to the banks’ viability if this vendor was disrupted. In such a scenario, further
diversification of third party vendors would be needed.
to continually invest
It is expected that regulators will use their insights to provide feedback to
in and upgrade their banks and play an active role in shaping the industry’s response to the new
infrastructure under the requirements.
This will involve more effort to align enterprise-wide roles and responsibilities.
Operational resilience practices will need to become embedded in day-to-day
operations, and all employees will need to think about their roles and how they
contribute to the bank’s connected operational resilience model with stability.
Moving forward, banks will need to carry out regular monitoring of their
capabilities including an annual exercise to challenge their operational resilience
framework. They will also need to continually invest in and upgrade their
infrastructure under the OR-2 guidelines.
The need to fulfil the regulatory requirements of OR-2 has been a major incentive
for banks to continually monitor and upgrade their operational resilience.
However, banks in Hong Kong also recognise that being able to deliver their
critical operations through disruption is fundamental to their viability and vital for
market stability.
Disruption is becoming a new normal: for example, some leading social media
platforms have experienced significant interruptions to their service in recent
times. And while the demise of Silicon Valley Bank in the US was not directly
related to operational resilience, this crisis serves as a reminder for banks to
prepare for disruptive situations, such as a lot of customers wanting to make
withdrawals at the same time, and the banks’ trading systems are more likely to
come under stress.
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60 Hong Kong Banking Report 2023
Banks should look at operational resilience from the perspective of both acute
disruption and ongoing maintenance and proactively think about what investment
is required:
Another potential issue for banks is regulatory risk, as regulators will sometimes
need to respond quickly to external events, which will impact how banks operate.
From a global perspective, Hong Kong is among the most advanced jurisdictions
in having a strong and comprehensive operational resilience regulatory framework
in place. While these regulatory requirements add complexity and demand effort
from the banks, they have considerable benefits.
When a large company has interruptions to its services it often makes global
headlines and can be disastrous for the company’s reputation. For banks, it is
particularly important that disruptions are dealt with swiftly. A strong operational
resilience system means that banks can recover quickly from any disruption and
avoid having a detrimental impact on their clients, from retail customers to major
global corporates.
Ultimately, operational resilience not only benefits banks and protects all their
customers, but also plays a crucial role in strengthening the foundations of Hong
Kong as a stable and secure global finance hub.
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Hong Kong Banking Report 2023 61
Banking Turmoil
A side effect of this policy has been a significant impact on the value of bonds,
in particular longer term bonds, which lost market value of as much as 30%.
For banks that were holding a large amount of these bonds and similar types of
securities, this would become a major issue.
The reason that some banks were holding so many of these bonds was due to
their high level of deposits. The boom of the past few years had resulted in a
huge inflow of deposits to banks during 2020 and 2021. Some banks chose to
invest a lot of these deposits in long-term mortgage-backed securities and bonds,
but this meant that they were highly vulnerable when interest rates rose and the
fair value of the bonds dropped.
At the same time, as the global economy cooled in 2022 and the amount of
deposits shrunk, banks needed to adjust their balance sheets and sold some of
the available-for-sale (AFS) securities at a loss. Customers were spooked by this
unexpected development, and many of them rushed to transfer their deposits.
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62 Hong Kong Banking Report 2023
On the asset side, banks should remember that focusing too much investment
in longer term bonds, without hedging their assets, means they will be more
seriously affected by the impact of interest rate rises.
On the liability side, banks should be alert to concentration risk. Similar types
of customers demonstrate similar behaviours, which becomes a problem if
certain customers want to make large withdrawals. This includes have too many
customers concentrated in the same industry, or customers with high levels of
deposits that are not covered by their respective government’s insurance level
for bank deposits.
Another area to look out for is a mismatch in the duration of assets and liabilities.
A mismatch is normal practice for banks so they can gain a higher return on
their assets, but banks should take care that it doesn’t start to grow far beyond
industry norms.
Some other key issues that banks could consider include governance. Banks
must pay close attention to all the regulatory demands in the jurisdictions where
they operate. However, in cases where regulations have eased, banks should
perhaps consider the impact from a risk perspective and check whether lower
regulatory demands may have other consequences for their operations. Banks
should also ensure that they have a well-resourced Risk Management function
that has the expertise and knowledge to flag up any issues sooner rather than
later.
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Hong Kong Banking Report 2023 63
A third point that banks should consider is the disconnect between accounting
and risk regulation. From an accounting perspective, some assets are measured
at amortised cost, meaning that they are valued at the initial purchase cost, not at
fair value. But when these assets are sold, they can only be sold at market value.
This could end up being a lot lower than the initial cost. Banks should be aware
of this possible disconnect to ensure that they have a realistic view of the market
value of their assets, especially when those bonds could potentially be the source
of liquidity to cover large cash outflow.
While the global banking turmoil seems to have eased, there may be wider
repercussions. There has been a significant move of deposits out of smaller
banks to larger banks. This pattern could affect the property sector as most
commercial real estate loans in the US are held by medium and small banks. If a
significant number of customers move their deposits, this could potentially trigger
a crisis in commercial real estate loans, and in turn lower the price of commercial
real estate.
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64 Hong Kong Banking Report 2023
Sophisticated High-Net-
Worth Investors
New proposal to streamline selling processes and
clarify guidance aims to boost the wealth management
sector
The growing number of high-net-worth individuals across Asia means that wealth
management services are increasingly in demand. Banks in Hong Kong are ideally
placed to offer these clients the expertise they need, but they need to have the
Angela Wong right products on offer, supported by a sales process that ensures clients are
Director, able to easily and efficiently invest in the products available while providing an
appropriate level of investor protection.
Governance, Risk and
Compliance Services, The availability of a broad range of investment products, including relatively
Hong Kong sophisticated complex products, is a key part of Hong Kong’s attractiveness
KPMG China as a wealth management hub. However, the suitability requirements that has
developed over the last decade in Hong Kong to protect investors who may not
sufficiently understand investment products and their associated risks has been
seen by some in the industry as excessive when servicing sophisticated and
knowledgeable customers.
To ensure that Hong Kong remains competitive in this area, the Hong Kong
Monetary Authority and the Securities and Futures Commission have recently
been engaging the private wealth management industry to review Hong Kong’s
wealth management framework, and have proposed a new Sophisticated
High-Net-Worth Investor (SHNWI) initiative to streamline or waive selected
requirements of the process of product suitability and risk disclosure.
The proposal aims to ensure that the regulators take a balanced approach
regarding the obligations placed on wealth managers when serving sophisticated
high-net-worth investors. In practice, this means a regulatory regime that is
user friendly for customers while still being robust enough to provide investor
protection.
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Hong Kong Banking Report 2023 65
But it is also because some banks have been cautious in making these
judgements. For example, some banks have not made full use of the regulatory
flexibility that is allowed, or they have adopted very conservative risk and
concentration thresholds. Furthermore, some banks have been conducting
additional suitability assessments that are not required.
In this regard, banks are simply being prudent. Their compliance and internal
auditor functions may have adopted more stringent measures to make sure there
are no breaches of regulation. But this has led to a frustrating experience for
some investors, who have had to endure a lengthy investment product selling
process due to the bank’s strict requirements.
At the same time, taking a very conservative suitability approach means that
banks might be missing out on the business opportunities in this dynamic and
growing segment of the market.
The initiative aims to reduce or remove undue delay or obstacles from the selling
process for sophisticated high-net-worth investors by streamlining areas of
product due diligence, suitability assessment and product disclosure, while also
providing proportionate investor protection.
While the SHMWI guidance has not yet been finalised, it is expected that to
qualify as a sophisticated high-net-worth investor, clients must have AUM of
a certain level and must also be able to demonstrate that they have previous
investment knowledge and experience, which can be from work or academic
experience. Those investors that qualify will then be eligible for the streamlined
processes and increased flexibility.
Ultimately, it will be up to the banks to decide if they want to adopt this flexibility.
But it is expected that when the proposal takes effect, banks will be more
confident in supporting the initiative given the clear guidance from the regulators.
This will benefit both banks and customers: investors will enjoy easier access
to the products they are interested in, while banks can conduct more business
while offering a better customer experience.
Other guidelines have been issued by the regulators in the past to help banks
interpret the rules and understand exactly what is allowed in terms of regulatory
flexibility. However, the SHWI initiative should provide greater clarification and
ultimately help to attract more wealth management clients to Hong Kong.
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
66 Hong Kong Banking Report 2023
Balancing act
The cycle of regulatory requirements and guidelines around investment products
has been seen before. After the global financial crisis and the related mini-bonds
crisis in 2008 that affected many Hong Kong investors, regulatory measures were
tightened significantly, and the HKMA started issuing regulatory circulars on top
of the SFC requirements. After a decade or so, regulations had eased somewhat,
but banks in Hong Kong have remained relatively cautious.
Regulators have a difficult balancing act in terms of the guidance they provide. If
it is too prescriptive, banks don’t have the leeway to serve their customers well.
But a more flexible environment can lead to overly prudent practice as banks
don’t want to take the risk or possibly misunderstand the regulatory standards.
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 67
Changing landscape
In terms of their adoption of data analytics platforms, banks in Hong Kong are
doing well compared to global standards. Part of this is due to encouragement
from the HKMA, who have made it a regulatory focus in recent years and have
also been keeping track of adoption and activity.
But while data analytics platforms are not a new development for banks, the
technology changes constantly as new innovations emerge, and banks need to
keep up to date. Banks have become skilled in using traditional and existing data
sets in recent years. However, to really benefit from data analysis they should
also be making use of the new types of data sets that are emerging, to better
understand customer behaviour and to spot any anomalies.
A key challenge currently for banks is ensuring that they are able to use the new
data that is becoming available as a result of the changes in the overall banking
infrastructure and the increasing use of mobile devices for banking by customers.
If they are to take advantage of this wealth of new data, banks will need to have
the right platforms and qualified people in place – whether in-house or by using
third party service providers.
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68 Hong Kong Banking Report 2023
Hong Kong’s new virtual banks have an advantage in some respects when it
comes to data analysis. As these banks are entirely online, their customers’
footprints are therefore entirely digital. This gives the virtual banks a more
complete picture of customer activity, with whole new sets of data points
including IP addresses, location and even biometric footprints. For example, they
can identify if a customer is logging in from a different device than usual.
Traditional banks are also benefitting from these new data sets as their
customers are also increasingly using mobile devices for banking. In addition,
seeing some of the headway that the virtual banks are making in this area has
nudged the bigger banks to adopt some of the new technology. The major banks
in Hong Kong also have the advantage of more data to use from their large
customer base.
Moving forward
As data analytics becomes ever more important for banks, a number of questions
are emerging about how to move forward. One of the key areas for consideration
is the use of outsourcing.
Banks have been using data analytics for some time, but as the landscape
evolves there are good reasons for banks to take a fresh look at how they are
using data analytics platforms and the related staff. Over the years, as the
technology initially developed, banks hired a lot of data scientists and other
experts in areas including cybersecurity and forensics to run their data analytics
platforms. These highly qualified staff members also require high salaries, so
come at a significant cost.
But these earlier types of data science have now become “business-as-usual”
for banks, so they are now asking if their high-salaried staff members need
to continue focusing on these areas. If such types of data analysis can be
outsourced, this will save costs, and allow the banks’ top-level data scientists to
focus on the next generation of technology and innovation.
There are a number of well-established third party vendors in the market that
can provide specialised data analytics platforms that offer a more cost-effective
option.
One of the key benefits of data analytics platforms is that they have removed a
lot of the mundane work for banking staff. Banks therefore do not need so many
employees engaged in low-skilled activity as in the past.
More recently, as the technology has become more sophisticated, data analytics
platforms are increasingly able to carry out some of the more complex analytic
work. This is freeing data scientists to use their expertise to look ahead and focus
on identifying the new analytics development that will help banks strengthen
their resilience and improve their services.
Now that the pandemic restrictions have been removed in Hong Kong, it is a
good opportunity for banks to review their workforce and operations. This should
include the use of data analytics platforms, which can not only improve efficiency
and save costs, but will also free up banking employees to do more meaningful
work.
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 69
Financial
highlights
Performance rankings:
• Licensed banks
• Virtual banks
• Deposit-taking companies
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Performance rankings
Licensed banks
Ranking Total assets HK$ million Ranking Net profit after tax HK$ million Ranking Cost/income ratio
Hongkong And Shanghai Banking Hongkong And Shanghai Banking Bank of Communications (Hong
1. 10,324,152 1. 82,104 1. 26.8%
Corporation Limited (The) Corporation Limited (The) Kong) Limited
2. Bank of China (Hong Kong) Limited 3,491,124 2. Bank of China (Hong Kong) Limited 29,587 2. Bank of China (Hong Kong) Limited 28.9%
Standard Chartered Bank (Hong Industrial And Commercial Bank of
3. 2,478,009 3. Hang Seng Bank, Limited 10,151 3. 30.4%
Kong) Limited China (Asia) Limited
Standard Chartered Bank (Hong Kong)
4. Hang Seng Bank, Limited 1,893,805 4. 6,298 4. Shanghai Commercial Bank Limited 34.7%
Limited
Industrial And Commercial Bank of Industrial And Commercial Bank of
5. 924,820 5. 6,023 5. Nanyang Commercial Bank, Limited 36.2%
China (Asia) Limited China (Asia) Limited
6. Bank of East Asia, Limited (The) 882,825 6. DBS Bank (Hong Kong) Limited 5,554 6. CMB Wing Lung Bank Limited 38.0%
7. Nanyang Commercial Bank, Limited 541,677 7. Bank of East Asia, Limited (The) 4,378 7. Chong Hing Bank Limited 38.6%
China Construction Bank (Asia)
8. DBS Bank (Hong Kong) Limited 475,875 8. Nanyang Commercial Bank, Limited 3,908 8. 39.0%
Corporation Limited
Bank of Communications (Hong China Construction Bank (Asia)
9. 467,012 9. 3,089 9. Hang Seng Bank, Limited 43.5%
Kong) Limited Corporation Limited
China Construction Bank (Asia)
10. 460,448 10. CMB Wing Lung Bank Limited 2,958 10. DBS Bank (Hong Kong) Limited 44.1%
Corporation Limited
Restricted licence banks
Ranking Total assets HK$ million Ranking Net profit after tax HK$ million Ranking Cost/income ratio
Bank of Shanghai (Hong Kong) Kasikornbank Public Company
1. 29,023 1. Citicorp International Limited 1,760 1. 7.3%
Limited Limited
Banc of America Securities Asia J.P. Morgan Securities (Asia Pacific)
2. 26,300 2. 1,392 2. KDB Asia Limited 18.0%
Limited Limited
Kasikornbank Public Company Banc of America Securities Asia
3. 22,634 3. KDB Asia Limited 326 3. 22.2%
Limited Limited
Siam Commercial Bank Public
4. KDB Asia Limited 22,560 4. Kasikornbank Public Company Limited 260 4. 46.7%
Company Limited (The)
J.P. Morgan Securities (Asia Pacific) Bank of Shanghai (Hong Kong)
5. 19,221 5. Banc of America Securities Asia Limited 208 5. 51.6%
Limited Limited
Siam Commercial Bank Public
6. 10,326 6. ORIX Asia Limited 79 6. Citicorp International Limited 57.0%
Company Limited (The)
Allied Banking Corporation (Hong
7. Korea Development Bank (The) 8,322 7. Habib Bank Zurich (Hong Kong) Limited 39 7. 59.0%
Kong) Limited
Allied Banking Corporation (Hong Kong) Habib Bank Zurich (Hong Kong)
8. Bank of China International Limited 6,405 8. 21 8. 64.9%
Limited Limited
9. Citicorp International Limited 4,376 9. Goldman Sachs Asia Bank Limited 18 9. Goldman Sachs Asia Bank Limited 68.2%
Siam Commercial Bank Public Company
10. ORIX Asia Limited 4,068 10. 15 10. ORIX Asia Limited 71.0%
Limited (The)
Deposit-taking companies
Ranking Total assets HK$ million Ranking Net profit after tax HK$ million Ranking Cost/income ratio
1. Public Finance Limited 6,342 1. Public Finance Limited 173 1. BCOM Finance (Hong Kong) Limited 12.5%
2. Kexim Asia Limited 5,597 2. Woori Global Markets Asia Limited 61 2. Woori Global Markets Asia Limited 32.0%
3. Woori Global Markets Asia Limited 3,674 3. Kexim Asia Limited 36 3. Chong Hing Finance Limited 38.0%
4. KEB Hana Global Finance Limited 1,326 4. KEB Hana Global Finance Limited 28 4. Kexim Asia Limited 38.6%
5. Vietnam Finance Company Limited 520 5. BPI International Finance Limited 6 5. KEB Hana Global Finance Limited 45.0%
6. BPI International Finance Limited 398 6. BCOM Finance (Hong Kong) Limited 6 6. Public Finance Limited 56.3%
Commonwealth Finance Corporation Commonwealth Finance Corporation
7. Corporate Finance (D.T.C.) Limited 328 7. 2 7. 82.4%
Limited Limited
8. BCOM Finance (Hong Kong) Limited 278 8. Vietnam Finance Company Limited 1 8. Corporate Finance (D.T.C.) Limited 85.7%
Commonwealth Finance Corporation
9. 258 9. Corporate Finance (D.T.C.) Limited 1 9. BPI International Finance Limited 88.3%
Limited
10. Fubon Credit (Hong Kong) Limited 97 10. Chong Hing Finance Limited - 10. Vietnam Finance Company Limited 88.9%
2. Citibank, N.A. 590,089 2. Citibank, N.A. 4,038 2. Agricultural Bank of China Limited 10.1%
3. Mizuho Bank, Ltd. 444,774 3. Agricultural Bank of China Limited 3,643 3. First Commercial Bank, Ltd. 12.8%
4. Bank of Communications Co., Ltd. 353,564 4. China Development Bank 2,782 4. China Merchants Bank Co., Ltd. 13.2%
5. MUFG Bank, Ltd. 351,436 5. DBS Bank Ltd. 2,709 5. KEB Hana Bank 13.6%
6. BNP Paribas 315,015 6. China Merchants Bank Co., Ltd. 2,086 6. Kookmin Bank 13.9%
JPMorgan Chase Bank, National
7. 302,879 7. United Overseas Bank Ltd. 2,059 7. Hua Nan Commercial Bank, Ltd. 14.4%
Association
Sumitomo Mitsui Banking
8. 302,801 8. China Minsheng Banking Corp., Ltd. 1,576 8. China Development Bank 14.6%
Corporation
Mega International Commercial Bank
9. DBS Bank Ltd. 302,115 9. Industrial Bank Co., Ltd. 1,503 9. 15.2%
Co., Ltd.
10. China Development Bank 266,127 10. Bank of America, National Association 1,439 10. Industrial Bank Co., Ltd. 17.4%
Source: Extracted from individual banks’ financial and public statements
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 71
Licensed banks
Ranking Return on equity Ranking Growth in assets Ranking Growth in net profit after tax
1. DBS Bank (Hong Kong) Limited 12.8% 1. Chong Hing Bank Limited 10.0% 1. Tai Yau Bank, Limited 106.7%
2. Bank of China (Hong Kong) Limited 9.6% 2. Fubon Bank (Hong Kong) Limited 9.7% 2. Fubon Bank (Hong Kong) Limited 40.7%
Hongkong And Shanghai Banking
3. 8.8% 3. Citibank (Hong Kong) Limited 9.5% 3. Bank of China (Hong Kong) Limited 22.1%
Corporation Limited (The)
4. Morgan Stanley Bank Asia Limited 7.6% 4. China CITIC Bank International Limited 8.2% 4. Nanyang Commercial Bank, Limited 21.0%
5. Shanghai Commercial Bank Limited 7.6% 5. DBS Bank (Hong Kong) Limited 6.3% 5. DBS Bank (Hong Kong) Limited 16.9%
Hongkong And Shanghai Banking
6. Nanyang Commercial Bank, Limited 6.1% 6. OCBC Wing Hang Bank Limited 4.3% 6. 13.2%
Corporation Limited (The)
Hongkong And Shanghai Banking
7. CMB Wing Lung Bank Limited 5.6% 7. 4.2% 7. OCBC Wing Hang Bank Limited 6.9%
Corporation Limited (The)
Industrial And Commercial Bank of
8. Hang Seng Bank, Limited 5.5% 8. Hang Seng Bank, Limited 4.0% 8. 6.3%
China (Asia) Limited
9. OCBC Wing Hang Bank Limited 5.5% 9. Chiyu Banking Corporation Limited 2.6% 9. China CITIC Bank International Limited 5.9%
10. Dah Sing Bank, Limited 5.1% 10. Wing Lung Bank Limited 2.2% 10. Wing Lung Bank Limited -2.4%
2. Mox Bank Limited 10,414 2. Airstar Bank Limited (200) 2. Mox Bank Limited 8,365
3. Fusion Bank Limited 4,371 3. Ant Bank (Hong Kong) Limited (203) 3. Fusion Bank Limited 3,437
4. Livi Bank Limited 4,098 4. Welab Bank Limited (458) 4. Livi Bank Limited 3,098
6. Welab Bank Limited 2,689 6. Fusion Bank Limited (533) 6. Welab Bank Limited 1,978
7. Airstar Bank Limited 2,660 7. Mox Bank Limited (631) 7. Airstar Bank Limited 1,799
8. Ant Bank (Hong Kong) Limited 1,443 8. Livi Bank Limited (715) 8. Ant Bank (Hong Kong) Limited 354
2. Bank of Dongguan Co., Ltd. 536.6% 2. Sumitomo Mitsui Trust Bank, Limited 1877.8%
7. China Guangfa Bank Co., Ltd. 65.3% 7. Taiwan Business Bank 700.0%
1 Bank of China (Hong Kong) Limited 31-Dec-22 34,790 20,529 15,967 39,352 2,545 1,291
2 Bank of Communications (Hong Kong) Limited 31-Dec-22 5,494 876 1,705 4,665 1,825 (39)
3 Bank of East Asia, Limited (The) 31-Dec-22 13,508 4,446 9,224 8,730 5,416 (1,627)
4 China CITIC Bank International Limited 31-Dec-22 6,896 1,567 4,099 4,364 1,900 (85)
6 Chiyu Banking Corporation Limited 31-Dec-22 1,803 1,134 1,334 1,603 554 4
7 Chong Hing Bank Limited 31-Dec-22 3,984 1,122 1,973 3,133 2,030 (162)
8 Citibank (Hong Kong) Limited 31-Dec-22 3,101 3,545 5,221 1,425 137 7
9 CMB Wing Lung Bank Limited 31-Dec-22 5,611 2,037 2,907 4,741 1,332 (60)
10 Dah Sing Bank, Limited 31-Dec-22 4,372 2,444 3,026 3,790 784 1,056
11 DBS Bank (Hong Kong) Limited 31-Dec-22 8,272 4,346 5,570 7,048 370 20
12 Fubon Bank (Hong Kong) Limited 31-Dec-22 1,607 368 1,046 929 288 (10)
13 Hang Seng Bank, Limited 31-Dec-22 28,981 4,991 14,778 19,194 7,669 86
Hongkong And Shanghai Banking Corporation
14 31-Dec-22 126,852 78,840 110,508 95,184 15,503 (17,930)
Limited (The)
Industrial And Commercial Bank of China (Asia)
15 31-Dec-22 9,735 2,758 3,798 8,695 1,169 255
Limited
16 Morgan Stanley Bank Asia Limited 31-Dec-22 711 2,833 2,605 939 - -
17 Nanyang Commercial Bank, Limited 31-Dec-22 7,172 2,478 3,490 6,160 1,535 181
18 OCBC Wing Hang Bank Limited 31-Dec-22 5,329 2,010 3,846 3,493 784 (234)
19 Public Bank (Hong Kong) Limited 31-Dec-22 1,156 208 830 534 131 -
20 Shanghai Commercial Bank Limited 31-Dec-22 3,887 1,265 1,790 3,362 271 (111)
21 Standard Chartered Bank (Hong Kong) Limited 31-Dec-22 27,169 22,430 32,513 17,086 6,733 1,532
Total excluding HSBCN2 2022 179,365 83,529 118,849 144,045 36,786 1,916
Total excluding BOCHK & HSBCN2 2022 144,575 63,000 102,882 104,693 34,241 625
* This is Liquidity Coverage Ratio.
# This is Liquidity Maintenance Ratio.
N1 This does not include Hang Seng Bank, as it is already included in the results of The Hongkong and Shanghai Banking Corporation.
N2 This include Hang Seng Bank.
N3 ROA is calculated as net profit after tax divided by average total assets.
N4 ROE is calculated as net profit after tax divided by average total equity.
Financial highlights
Size and strength measures
Profit Net profit Total Gross Expected Total Total Capital Liquidity
before tax after tax assets advances to credit loss deposits from equity adequacy ratio
customers allowance customers ratio
against
customer
advances
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
74 Hong Kong Banking Report 2023
Key ratios
Performance measures
HK$ million Year ended Net customer Net interest Non-interest Cost/ ROAN3 ROEN4
loan/deposit income/ income/total income
ratio average operating ratio
total income
assets
1 Bank of China (Hong Kong) Limited 31-Dec-22 69.1% 1.0% 37.1% 28.9% 0.9% 9.6%
2 Bank of Communications (Hong Kong) Limited 31-Dec-22 61.5% 1.2% 13.8% 26.8% 0.5% 4.8%
3 Bank of East Asia, Limited (The) 31-Dec-22 83.8% 1.5% 24.8% 51.4% 0.5% 3.9%
4 China CITIC Bank International Limited 31-Dec-22 72.1% 1.6% 18.5% 48.4% 0.5% 4.3%
China Construction Bank (Asia) Corporation
5 31-Dec-22 76.7% 1.2% 26.9% 39.0% 0.6% 4.1%
Limited
6 Chiyu Banking Corporation Limited 31-Dec-22 62.1% 1.0% 38.6% 45.4% 0.5% 4.9%
7 Chong Hing Bank Limited 31-Dec-22 73.3% 1.5% 22.0% 38.6% 0.4% 3.2%
8 Citibank (Hong Kong) Limited 31-Dec-22 47.2% 0.9% 53.3% 78.6% 0.3% 4.5%
9 CMB Wing Lung Bank Limited 31-Dec-22 66.9% 1.4% 26.6% 38.0% 0.8% 5.6%
10 Dah Sing Bank, Limited 31-Dec-22 69.3% 1.7% 35.9% 44.4% 0.6% 5.1%
11 DBS Bank (Hong Kong) Limited 31-Dec-22 70.0% 1.8% 34.4% 44.1% 1.2% 12.8%
12 Fubon Bank (Hong Kong) Limited 31-Dec-22 66.3% 1.3% 18.6% 53.0% 0.4% 3.6%
13 Hang Seng Bank, Limited 31-Dec-22 74.5% 1.6% 14.7% 43.5% 0.5% 5.5%
Hongkong And Shanghai Banking Corporation
14 31-Dec-22 60.6% 1.3% 38.3% 53.7% 0.8% 8.8%
Limited (The)
Industrial And Commercial Bank of China (Asia)
15 31-Dec-22 79.9% 1.1% 22.1% 30.4% 0.7% 4.2%
Limited
16 Morgan Stanley Bank Asia Limited 31-Dec-22 55.0% 1.0% 79.9% 73.5% 1.2% 7.6%
17 Nanyang Commercial Bank, Limited 31-Dec-22 79.4% 1.3% 25.7% 36.2% 0.7% 6.1%
18 OCBC Wing Hang Bank Limited 31-Dec-22 81.7% 1.6% 27.4% 52.4% 0.8% 5.5%
19 Public Bank (Hong Kong) Limited 31-Dec-22 79.5% 3.0% 15.2% 60.9% 0.8% 5.0%
20 Shanghai Commercial Bank Limited 31-Dec-22 54.4% 1.7% 24.6% 34.7% 1.1% 7.6%
21 Standard Chartered Bank (Hong Kong) Limited 31-Dec-22 69.7% 1.1% 45.2% 65.6% 0.3% 3.4%
22 Tai Sang Bank Limited 31-Dec-22 107.9% 1.0% 65.5% 117.2% -0.5% -0.7%
23 Tai Yau Bank, Limited 31-Dec-22 0.0% 0.9% 0.0% 94.1% 0.1% 0.1%
Total excluding HSBCN2 2022 71.3% 1.3% 31.8% 45.2% 0.6% 5.9%
Total excluding BOCHK & HSBCN2 2022 72.0% 1.3% 30.4% 49.6% 0.5% 4.9%
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 75
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Restricted licence banks – Financial highlights
Income statement
HK$ million Year ended Net Non-interest Operating Operating Change in Other
interest income expenses profit before expected items
income impairment credit loss
charges against
customer
advances
Allied Banking Corporation (Hong Kong)
1 31-Dec-22 52 9 36 25 - -
Limited
4 Bank of Shanghai (Hong Kong) Limited 31-Dec-22 516 (68) 231 217 408 449
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Hong Kong Banking Report 2023 77
Financial highlights
Size and strength measures
Profit Net profit Total Gross Expected Total Total Capital Liquidity
before tax after tax assets advances credit loss deposits equity adequacy ratio#
to allowance from ratio
customers against customers
customer
advances
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
78 Hong Kong Banking Report 2023
Key ratios
Performance measures
HK$ million Year ended Net customer Net interest Non-interest Cost/ ROA ROE
loan/deposit income/ income/total income ratio
ratio average total operating
assets income
2 Banc of America Securities Asia Limited 31-Dec-22 N/A -1.5% 177.8% 22.2% 1.2% 4.8%
3 Bank of China International Limited 31-Dec-22 69.0% 1.2% 61.8% 95.7% 0.1% 0.6%
4 Bank of Shanghai (Hong Kong) Limited 31-Dec-22 147.4% 1.6% -15.2% 51.6% -1.9% -13.3%
5 Citicorp International Limited 31-Dec-22 N/A 0.2% 99.8% 57.0% 28.9% 36.6%
6 Goldman Sachs Asia Bank Limited 31-Dec-22 0.0% 1.9% 68.2% 68.2% 1.6% 1.9%
7 Habib Bank Zurich (Hong Kong) Limited 31-Dec-22 115.4% 2.8% 37.4% 64.9% 1.3% 6.7%
9 Kasikornbank Public Company Limited 31-Dec-22 N/A 1.1% 14.7% 7.3% 1.2% 5.9%
10 KDB Asia Limited 31-Dec-22 198775.0% 1.1% 46.4% 18.0% 1.3% 8.6%
11 Korea Development Bank (The) 31-Dec-22 N/A 0.1% 33.3% 266.7% -0.3% 95.8%
12 ORIX Asia Limited 31-Mar-22 608.0% 3.5% 37.3% 71.0% 1.8% 3.5%
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Hong Kong Banking Report 2023 79
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Deposit-taking companies – Financial highlights
Income statement
HK$ million Year ended Net Non-interest Operating Operating Change in Other
interest income expenses profit before expected items
income impairment credit loss
charges against
customer
advances
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 81
Financial highlights
Size and strength measures
Profit Net profit Total Risk-weighted Gross Expected Total Total Capital Liquidity
before tax after tax assets assets advances to credit loss deposits equity adequacy ratio#
(“RWA”) customers allowance from ratio
against customers
customer
advances
207 173 6,342 4,810 5,090 132 4,294 1,647 28.9% 74.3%
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
82 Hong Kong Banking Report 2023
Key ratios
Performance measures
HK$ million Year ended Net customer Net interest Non-interest Cost/ ROA ROE
loan/deposit income/ income/ income
ratio average total total ratio
assets operating
income
1 BCOM Finance (Hong Kong) Limited 31-Dec-22 0.0% 0.0% 100.0% 12.5% 2.2% 2.2%
2 BPI International Finance Limited 31-Dec-22 48.4% 1.6% 90.0% 88.3% 1.6% 4.0%
4 Chong Hing Finance Limited 31-Dec-22 N/A 1.2% 0.0% 38.0% 0.6% 0.6%
6 Corporate Finance (D.T.C.) Limited 31-Dec-22 80.1% 2.1% 0.0% 85.7% 0.3% 1.0%
7 Fubon Credit (Hong Kong) Limited 31-Dec-22 N/A 0.0% 111.9% 11593.2% -7.3% -8.0%
8 KEB Hana Global Finance Limited 31-Dec-22 N/A 2.0% 53.3% 45.0% 2.0% 4.9%
9 Kexim Asia Limited 31-Dec-22 N/A 1.2% 7.1% 38.6% 0.7% 2.8%
10 Public Finance Limited 31-Dec-22 115.5% 9.4% 15.8% 56.3% 2.7% 10.5%
11 Vietnam Finance Company Limited 31-Dec-22 1041.1% 1.3% 0.0% 88.9% 0.1% 0.7%
12 Woori Global Markets Asia Limited 31-Dec-22 N/A 1.8% 34.0% 32.0% 1.6% 6.0%
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 83
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Foreign bank branches – Financial highlights
Income statement
HK$ million Year ended Net interest Non-interest Operating Operating Change in
income income expenses profit before expected credit
impairment loss against
charges customer
advances
1 Agricultural Bank of China Limited 31-Dec-22 3,979 1,052 506 4,525 125
2 Australia And New Zealand Banking Group Limited 30-Sep-22 903 657 917 643 23
3 Banco Bilbao Vizcaya Argentaria S.A. 31-Dec-22 347 227 294 280 (7)
4 Banco Santander, S.A. 31-Dec-22 262 591 760 93 (3)
5 Bangkok Bank Public Company Limited 31-Dec-22 424 154 167 411 105
6 Bank J. Safra Sarasin AG 31-Dec-22 229 304 528 5 -
7 Bank Julius Baer & Co. Ltd. 31-Dec-22 778 1,863 2,057 584 1
8 Bank of America, National Association 31-Dec-22 1,273 1,554 1,548 1,279 (488)
9 Bank of China Limited 31-Dec-22 130 109 130 109 -
10 Bank of Communications Co., Ltd. 31-Dec-22 2,295 854 1,470 1,679 908
11 Bank of Dongguan Co., Ltd. 31-Dec-22 106 11 111 6 -
12 Bank of India 31-Mar-22 57 167 41 183 6
13 Bank of Montreal 31-Oct-22 32 307 232 107 -
14 Bank of New York Mellon (The) 31-Dec-22 372 566 565 373 -
15 Bank of Nova Scotia (The) 31-Oct-22 212 81 257 36 -
16 Bank of Singapore Limited 31-Dec-22 132 872 719 285 -
17 Bank of Taiwan 31-Dec-22 146 5 37 114 (42)
18 Bank Sinopac 31-Dec-22 532 240 190 582 80
19 Banque Pictet & Cie Sa 31-Dec-22 76 220 481 (185) -
20 Barclays Bank PLC 31-Dec-22 39 2,813 2,029 823 6
21 BDO Unibank, Inc. 31-Dec-22 129 24 35 118 1
22 BNP Paribas 31-Dec-22 2,880 3,960 5,036 1,804 595
23 CA Indosuez (Switzerland) SA 31-Dec-22 56 283 344 (5) -
24 Canadian Imperial Bank of Commerce 31-Oct-22 82 431 217 296 2
25 Cathay Bank 31-Dec-22 58 12 45 25 2
26 Cathay United Bank Company, Limited 31-Dec-22 326 245 200 371 30
27 Chang Hwa Commercial Bank, Ltd. 31-Dec-22 191 24 41 174 (2)
28 Chiba Bank, Ltd. (The) 31-Mar-22 45 2 25 22 -
29 China Bohai Bank Co., Ltd. 31-Dec-22 44 20 153 (89) 7
30 China Construction Bank Corporation 31-Dec-22 1,169 907 725 1,351 (220)
31 China Development Bank 31-Dec-22 1,742 1 255 1,488 (1,296)
32 China Everbright Bank Co., Ltd. 31-Dec-22 1,214 501 419 1,296 729
33 China Guangfa Bank Co., Ltd. 31-Mar-22 99 91 119 71 35
34 China Merchants Bank Co., Ltd. 31-Dec-22 1,910 959 378 2,491 3
35 China Minsheng Banking Corp., Ltd. 31-Dec-22 1,875 760 475 2,160 297
36 China Zheshang Bank Co., Ltd. 31-Dec-22 343 472 168 647 37
* Some branches hold impairment allowances of head office
# Note that all are Liquidity Maintenance Ratio
Source: Extracted from individual companies’ financial and public statements
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 85
Financial highlights
Size and strength measures
Other Profit Net profit Total Gross advances Expected credit loss Total deposits Liquidity
items before after tax assets to customers allowance against from customers ratio#
tax customer advances*
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
86 Hong Kong Banking Report 2023
Income statement
HK$ million Year ended Net interest Non-interest Operating Operating Change in
income income expenses profit before expected credit
impairment loss against
charges customer
advances
57 Hua Xia Bank Co., Limited 31-Dec-22 459 106 226 339 62
60 Industrial And Commercial Bank of China Limited 31-Dec-22 1,027 177 436 768 (19)
61 Industrial Bank Co., Ltd. 31-Dec-22 1,841 1,109 512 2,438 608
65 JPMorgan Chase Bank, National Association 31-Dec-22 710 9,898 9,007 1,601 1,537
Financial highlights
Size and strength measures
Other Profit Net profit Total Gross advances Expected credit loss Total deposits Liquidity
items before after tax assets to customers allowance against from customers ratio#
tax customer advances*
- 69 68 41,117 - - - 73.9%
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
88 Hong Kong Banking Report 2023
Income statement
HK$ million Year ended Net interest Non-interest Operating Operating Change in
income income expenses profit before expected credit
impairment loss against
charges customer
advances
73 Mega International Commercial Bank Co., Ltd. 31-Dec-22 434 32 71 395 (5)
74 Mitsubishi UFJ Trust And Banking Corporation 31-Mar-22 228 (84) 58 86 -
81 Oversea-Chinese Banking Corporation Limited 31-Dec-22 726 192 409 509 276
82 Ping An Bank Co., Ltd. 31-Dec-22 366 334 322 378 477
85 Shanghai Commercial & Savings Bank, Ltd. (The) 31-Dec-22 198 32 46 184 127
86 Shanghai Pudong Development Bank Co., Ltd. 31-Dec-22 1,064 1,287 572 1,779 316
90 State Street Bank And Trust Company 31-Dec-22 298 1,405 1,413 290 -
91 Sumitomo Mitsui Banking Corporation 31-Mar-22 1,649 636 632 1,653 773
93 Taipei Fubon Commercial Bank Co., Ltd. 31-Dec-22 671 277 183 765 (17)
94 Taishin International Bank Co., Ltd 31-Dec-22 266 120 169 217 102
97 Taiwan Shin Kong Commercial Bank Co., Ltd. 31-Dec-22 156 4 56 104 (10)
103 United Overseas Bank Ltd. 31-Dec-22 2,496 1,068 772 2,792 315
Financial highlights
Size and strength measures
Other Profit Net profit Total Gross advances Expected credit loss Total deposits Liquidity
items before after tax assets to customers allowance against from customers ratio#
tax customer advances*
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Foreign bank branches – Financial highlights
(Continued)
Key ratios
Performance measures
HK$ million Year ended Net customer Net interest Non-interest Cost/
loan/deposit ratio income/ income/total income
average operating ratio
total assets income
1 Agricultural Bank of China Limited 31-Dec-22 141.2% 0.7% 20.9% 10.1%
2 Australia And New Zealand Banking Group Limited 30-Sep-22 164.5% 0.5% 42.1% 58.8%
3 Banco Bilbao Vizcaya Argentaria S.A. 31-Dec-22 4468.9% 0.6% 39.5% 51.2%
4 Banco Santander, S.A. 31-Dec-22 165.3% 0.3% 69.3% 89.1%
5 Bangkok Bank Public Company Limited 31-Dec-22 98.6% 0.6% 26.6% 28.9%
6 Bank J. Safra Sarasin AG 31-Dec-22 68.6% 1.2% 57.0% 99.1%
7 Bank Julius Baer & Co. Ltd. 31-Dec-22 60.8% 1.1% 70.5% 77.9%
8 Bank of America, National Association 31-Dec-22 136.2% 1.1% 55.0% 54.8%
9 Bank of China Limited 31-Dec-22 N/A 0.1% 45.6% 54.4%
10 Bank of Communications Co., Ltd. 31-Dec-22 81.7% 0.6% 27.1% 46.7%
11 Bank of Dongguan Co., Ltd. 31-Dec-22 1364.7% 1.5% 9.4% 94.9%
12 Bank of India 31-Mar-22 157.9% 0.4% 74.6% 18.3%
13 Bank of Montreal 31-Oct-22 178.2% 0.1% 90.6% 68.4%
14 Bank of New York Mellon (The) 31-Dec-22 21.8% 0.7% 60.3% 60.2%
15 Bank of Nova Scotia (The) 31-Oct-22 218.0% 0.5% 27.6% 87.7%
16 Bank of Singapore Limited 31-Dec-22 57.7% 0.5% 86.9% 71.6%
17 Bank of Taiwan 31-Dec-22 21.3% 1.1% 3.3% 24.5%
18 Bank Sinopac 31-Dec-22 39.8% 1.5% 31.1% 24.6%
19 Banque Pictet & Cie Sa 31-Dec-22 82.3% 0.4% 74.3% 162.5%
20 Barclays Bank PLC 31-Dec-22 0.9% 0.2% 98.6% 71.1%
21 BDO Unibank, Inc. 31-Dec-22 81.1% 2.1% 15.7% 22.9%
22 BNP Paribas 31-Dec-22 66.2% 0.9% 57.9% 73.6%
23 CA Indosuez (Switzerland) SA 31-Dec-22 37.6% 0.6% 83.5% 101.5%
24 Canadian Imperial Bank of Commerce 31-Oct-22 78.1% 0.2% 84.0% 42.3%
25 Cathay Bank 31-Dec-22 173.9% 1.5% 17.1% 64.3%
26 Cathay United Bank Company, Limited 31-Dec-22 78.3% 1.1% 42.9% 35.0%
27 Chang Hwa Commercial Bank, Ltd. 31-Dec-22 46.4% 1.6% 11.2% 19.1%
28 Chiba Bank, Ltd. (The) 31-Mar-22 994.2% 0.5% 4.3% 53.2%
29 China Bohai Bank Co., Ltd. 31-Dec-22 155.6% 0.5% 31.3% 239.1%
30 China Construction Bank Corporation 31-Dec-22 89.7% 0.5% 43.7% 34.9%
31 China Development Bank 31-Dec-22 282.1% 0.6% 0.1% 14.6%
32 China Everbright Bank Co., Ltd. 31-Dec-22 79.4% 0.6% 29.2% 24.4%
33 China Guangfa Bank Co., Ltd. 31-Mar-22 128.6% 0.4% 47.9% 62.6%
34 China Merchants Bank Co., Ltd. 31-Dec-22 20.8% 1.3% 33.4% 13.2%
35 China Minsheng Banking Corp., Ltd. 31-Dec-22 84.6% 0.9% 28.8% 13.2%
36 China Zheshang Bank Co., Ltd. 31-Dec-22 109.9% 0.7% 57.9% 20.6%
Source: Extracted from individual companies’ financial and public statements
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 91
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
92 Hong Kong Banking Report 2023
Key ratios
Performance measures
HK$ million Year ended Net customer Net interest Non-interest Cost/
loan/deposit ratio income/ income/total income
average operating ratio
total assets income
37 CIMB Bank Berhad 31-Dec-22 41.8% 0.2% 46.5% 207.0%
38 Citibank, N.A. 31-Dec-22 24.2% 1.3% 24.5% 47.0%
39 Commonwealth Bank of Australia 30-Jun-22 235.7% 0.8% 34.3% 155.7%
40 Coöperatieve Rabobank U.A. 31-Dec-22 341.1% 0.7% 38.5% 61.8%
41 Credit Agricole Corporate And Investment Bank 31-Dec-22 135.8% 0.2% 84.1% 51.0%
42 Crédit Industriel et Commercial 31-Dec-22 203.9% 0.4% 26.0% 48.0%
43 Credit Suisse AG 31-Dec-22 79.1% 0.9% 64.6% 96.5%
44 CTBC Bank Co., Ltd. 31-Dec-22 34.5% 1.7% 22.4% 27.3%
45 DBS Bank Ltd. 31-Dec-22 220.6% 0.7% 43.5% 20.3%
46 Deutsche Bank Aktiengesellschaft 31-Dec-22 44.7% 1.1% 61.6% 89.6%
DZ BANK AG Deutsche Zentral-Genossenschaftsbank,
47 31-Dec-22 1611.3% 0.6% 37.6% 95.1%
Frankfurt Am Main
48 E.Sun Commercial Bank, Ltd. 31-Dec-22 37.1% 1.5% -4.7% 21.4%
53 First Abu Dhabi Bank PJSC 31-Dec-22 17.9% 0.3% 39.7% 55.0%
56 Hua Nan Commercial Bank, Ltd. 31-Dec-22 35.2% 1.6% 4.8% 14.4%
57 Hua Xia Bank Co., Limited 31-Dec-22 235.9% 0.9% 18.8% 40.0%
60 Industrial And Commercial Bank of China Limited 31-Dec-22 N/A 0.5% 14.7% 36.2%
65 JPMorgan Chase Bank, National Association 31-Dec-22 24.1% 0.3% 93.3% 84.9%
69 Land Bank of Taiwan Co., Ltd. 31-Dec-22 117.3% 1.2% 6.7% 25.8%
72 Mashreq Bank - Public Shareholding Company 31-Dec-22 49790.9% 1.4% 21.8% 29.7%
Source: Extracted from individual companies’ financial and public statements
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 93
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
94 Hong Kong Banking Report 2023
Key ratios
Performance measures
HK$ million Year ended Net customer Net interest Non-interest Cost/
loan/deposit ratio income/ income/total income
average operating ratio
total assets income
73 Mega International Commercial Bank Co., Ltd. 31-Dec-22 20.9% 1.2% 6.9% 15.2%
74 Mitsubishi UFJ Trust And Banking Corporation 31-Mar-22 0.0% 0.7% -58.3% 40.3%
85 Shanghai Commercial & Savings Bank, Ltd. (The) 31-Dec-22 71.1% 2.2% 13.9% 20.0%
86 Shanghai Pudong Development Bank Co., Ltd. 31-Dec-22 73.1% 0.5% 54.7% 24.3%
90 State Street Bank And Trust Company 31-Dec-22 0.7% 0.5% 82.5% 83.0%
92 Sumitomo Mitsui Trust Bank, Limited 31-Mar-22 74.9% 0.0% 106.9% 35.3%
93 Taipei Fubon Commercial Bank Co., Ltd. 31-Dec-22 37.1% 1.1% 29.2% 19.3%
94 Taishin International Bank Co., Ltd 31-Dec-22 47.5% 1.1% 31.1% 43.8%
97 Taiwan Shin Kong Commercial Bank Co., Ltd. 31-Dec-22 40.5% 1.4% 2.5% 35.0%
101 Union Bancaire Privée, UBP SA 31-Dec-22 39.1% 1.2% 51.6% 84.2%
103 United Overseas Bank Ltd. 31-Dec-22 266.8% 1.1% 30.0% 21.7%
104 Wells Fargo Bank, National Association 31-Dec-22 N/A 0.0% 100.0% 95.1%
107 Yuanta Commercial Bank Co., Ltd. 31-Dec-22 9.7% 0.7% 18.2% 100.0%
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 95
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Virtual banks – Financial highlights
Financial highlights
Income statement
HK$ million Year ended Net Non- Operating Operating Change in Other Profit Net
interest interest expenses profit before expected items before profit
income income impairment credit loss tax after
charges against tax
customer
advances
2 Ant Bank (Hong Kong) Limited 31-Dec-22 15 2 219 (202) - 1 (203) (203)
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Hong Kong Banking Report 2023 97
Key ratios
Size and strength measures Performance measures
Total Gross Expected Total Total Capital Liquidity Net Net Non- Cost/ ROA ROE
assets advances to credit loss deposits equity adequacy ratio customer interest interest income
customers allowance from ratio loan/ income/ income/ ratio
against customers deposit average total
customer ratio total operating
advances assets income
2,660 839 38 1,799 758 49.8% 176.2% 44.5% 2.1% 3.1% 353.8% -6.8% -23.3%
1,443 48 1 354 1,017 241.1% 321.1% 13.3% 0.9% 11.8% 1288.2% -11.8% -18.3%
4,371 967 7 3,437 607 35.3% 209.6% 27.9% 0.2% 1902.0% -131881.2% -12.1% -66.8%
4,098 1,318 14 3,098 781 43.4% 154.6% 42.1% 0.2% 52.9% 4176.5% -16.9% -72.4%
10,414 5,044 87 8,365 1,383 19.0% 44.2% 59.3% 1.3% 32.9% 408.2% -7.3% -52.0%
3,193 1,799 13 2,147 848 98.3% 124.8% 83.2% 3.3% 3.1% 250.5% -5.5% -20.3%
2,689 1,443 33 1,978 502 31.5% 152.1% 71.3% 1.2% 22.7% 1056.8% -16.3% -90.4%
11,608 4,928 47 9,172 2,159 25.3% 76.9% 53.2% 1.8% 29.9% 263.9% -4.7% -21.5%
40,476 16,386 240 30,350 8,055 - - 53.2% 1.4% 22.8% 556.9% -8.9% -39.6%
© 2023 KPMG, a Hong Kong (SAR) partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
98 Hong Kong Banking Report 2023
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Hong Kong Banking Report 2023 99
Contact us
Bonn Liu Gemini Yang Guy Isherwood
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Hong Kong KPMG China KPMG China
KPMG China +852 3927 5731 +852 2978 8243
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