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Mandatory climate-risk disclosure to pose challenges for Hong Kong fund managers


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Mandatory climate-risk disclosure to pose challenges for Hong Kong fund managers

Uneven proficiency in assessing climate-related risks and transparency of portfolio companies will pose challenges for many fund managers in Hong Kong as the city is about to make environmental disclosures mandatory, experts say.

The Securities & Futures Commission has proposed sweeping disclosure requirements on all fund managers, from the involvement of the board and management to the adoption of tools and metrics to identify, assess, manage and monitor climate-related risks of their portfolios on an annual basis, according to the regulator's consultation paper.

Large fund managers, which have assets under management of over HK$4 billion, are subject to more requirements. Additional disclosures include scenario analysis and weighted average carbon intensity at a fund level, a metric recommended by the Task Force on Climate-related Financial Disclosures, or TCFD, according to the SFC. It did not say when the policy will become effective.

"Quantitative assessments, which are particularly relevant to large fund managers, will likely prove to be an onerous obligation," said Rolfe Hayden, a partner at law firm Simmons & Simmons in Hong Kong who specializes in asset management and financial services. Increased costs due to compliance is another concern, which is likely to have a bigger impact on smaller fund managers, Hayden said.

Hong Kong's plan comes as major economies in Asia-Pacific pledge to go carbon neutral in a few decades. Japan, South Korea and Hong Kong aim to achieve net-zero emissions by 2050, and Mainland China targets to meet the same goal by 2060.

The city's move also follows New Zealand, which in September 2020 announced a plan to require mandatory environmental-risk reporting for investment managers. Minister for Climate Change James Shaw said the nation will require all financial institutions, including funds with more than NZ$1 billion of assets under management, to make annual disclosures of climate risks based on the TCFD framework in 2023 at the earliest.

Meanwhile, most other economies in Asia-Pacific are still adopting voluntary disclosure regime. Mainland China, one of the world's largest green bond issuers, issued voluntary green investment guidelines in 2018. Singapore also issued proposed guidelines in June 2020 to encourage funds to manage climate risks based on international frameworks such as the TCFD.

Tough compliance

One of the challenges of mandatory disclosure is industry expertise.

Yvette Kwan, an executive adviser at the Asia Securities Industry & Financial Markets Association, said local fund managers in Hong Kong may find it tough to build up ESG expertise to fulfil compliance. "Proficiencies include risk identification, assessment, quantitative skills and compliance or legal knowledge as well as an understanding of ESG issues at the board and senior management level, all the way down to the actual calculation of ESG metrics such as greenhouse gas emissions of portfolios," she said.

Penelope Shen, the investment funds partner at law firm Stephenson Harwood in Hong Kong, added that smaller fund managers "will struggle to even start assessing the relevance and materiality of climate risk."

Shen pointed out that even fund managers who are aware of ESG matters would find it hard to even decide how to go about, for example, identifying climate-related risks, as in what kind of risks fit the SFC criteria, or what standards they should be referring to. They might also have to decide if they are prepared to incur costs to consult third-party service providers such as lawyers and accountants to see what might be needed, she added.

The SFC, she added, could consider providing support for those who are less familiar with climate risk, such as workshops and the setting up of dedicated online resources. "This will create a useful roadmap that will smoothen policy development," she said.

Tamami Ota, a senior researcher at Daiwa Institute of Research in Tokyo specializing in ESG research, said fund managers could find it tough to persuade asset owners to disclose ESG information, as owners are generally not used to such transparency.

The Hong Kong stock exchange launched its mandatory climate risk reporting regime for all listed companies in July 2020, although unlisted companies, which could be investment targets of smaller funds, are not subject to the new policy.

As of Feb. 5, US$1 was equivalent to NZ$1.39.