How to read the tables

Choosing private wealth services involves three independent dimensions: which type of institution (role), which service model (who decides each trade) and which client classification (which rules apply). None determines the others. The three tables below correspond to the three dimensions; all fees and thresholds are dated public examples and not a comparative conclusion.

Table 1: the four roles

Dimension Private bank External asset manager (EAM) Single family office Insurer
Legal status Authorized institution and registered institution Licensed corporation (Type 9 core, often 1/4) Family-owned company, usually unlicensed Authorized by the Insurance Authority
Supervisor HKMA (conduct); SFC (rules) SFC Generally no licensing supervisor; tax concession conditions set by the IRD Insurance Authority
Who holds the assets Client account at the bank; bank is custodian Custodian bank; the EAM holds nothing Family or its holding vehicles; custodied at banks Insurer's balance sheet; client holds a contractual right
Who decides trades Client (advisory/execution-only) or bank (discretionary) EAM (discretionary) or client (advisory) Family or its hired investment team Insurer (participating fund)
Threshold (published examples) Maintenance fee below US$2m (Standard Chartered Private Bank, July 2026) or HK$8m (Dah Sing, October 2026); regulatory definition US$3m / US$1m Set by each EAM, no published standard Tax concession requires HK$240m net assets among other conditions (2023 ordinance) Minimum premium set by product
Fee sources Custody, commissions, management fees, interest margin, rebates Management and performance fees, custodian retrocessions Family-borne staff and operating costs Charges inside premiums, spread between returns and bonuses
Where conflicts sit Role overlap, in-house products, rebates, insurance-plus-loan bundling Custodian retrocessions, product rebates Internal governance, between family members Sales commissions (via intermediaries), non-guaranteed bonuses
Exit Close or transfer the account; assets move Revoke the power of attorney; assets stay Dissolve or restructure Surrender at surrender value, policy loan, withdrawal
Suits Anyone needing custody, lending and execution Several custodians, independent decisions, consolidated reporting Wealth large and complex enough to fund a dedicated team Need for guaranteed value, death benefit and legacy functions
Scale 2024–2025 46 registered institutions reported the business; HK$12.9 trillion of assets (2025) 48 licensed corporations reported private banking business (2024) More than 3,380 single family offices (end-2025) Per Insurance Authority statistics

The most important row is who holds the assets: only banks and insurers hold anything, the former custodied assets and the latter the assets behind the contract; EAMs and family offices are decision layers. The threshold row mixes three different kinds of number—regulatory definition, maintenance fee lines and tax conditions—and should not be read as a ranking.

Table 2: the three service models

Dimension Discretionary Advisory Execution-only
Who decides each trade Manager Client Client
Legal basis Code of Conduct paragraphs 7.1–7.2 Paragraph 5.2 suitability; portfolio-based for private banking customers (HKMA 2012) Paragraphs 5.1A and 5.5 (derivatives and complex products)
Required documents Written authority, investment mandate, agreement designating a "discretionary account" Risk profile, investment mandate (private banking customers), client agreement Client agreement
Annual action Authority confirmed at least annually Risk profile reviewed at least every two years Per firm policy
Fee shape Management fee plus programme fee plus possible performance fee Commissions per trade or asset-based advisory fee Commissions or spread plus custody
Published example Standard Chartered Private Bank Signature: 1% set-up, top-up and transfer fees plus programme fees (July 2026) Wrap service fee up to 1.50% a year (July 2026) Listed securities commission up to 1.00%, minimum US$150 (July 2026)
Conflict location Product selection Trading frequency Pricing transparency

Table 3: the four client classifications

Dimension Retail client Private banking customer Professional investor Sophisticated professional investor
Basis Default HKMA circular of 12 June 2012 Securities and Futures (Professional Investor) Rules Joint circular of 28 July 2023
Threshold None US$3m investable assets or US$1m under the bank's management HK$8m portfolio (individual) Wealth, knowledge-or-experience and objective criteria
Suitability approach Per transaction Portfolio-based against the mandate Per transaction with some waivers No transaction-level matching; upfront product explanation
Products Retail Retail (per mandate) Non-retail products available Non-retail products available
Investor protection Fullest (audio recording, cooling-off) Flexible version Partly waived Voluntarily waived, with opt-out
Consent needed No Notification Confirmation of assets Written consent

Using the three tables together

Pick one item from each dimension and check that the combination is coherent. "Private bank + discretionary + professional investor" means the bank both custodies and decides, so the conflict sits in product selection and the in-house product share and rebate disclosure deserve attention. "EAM + discretionary + private banking customer at the custodian" separates decision from custody, so the limited power of attorney and the EAM's custodian retrocessions deserve attention. "Private bank + advisory + sophisticated professional investor" means transaction-level suitability protection has been waived and monitoring trading frequency falls to the client. Policies are a separate contractual layer in every combination; the Chinese pages explain their liquidity, leverage and legacy functions and the premium financing rules in force since 2023.

Sources and dates

  1. Asset and Wealth Management Activities Survey 2024 — Securities and Futures Commission (SFC) · 2025-07
  2. Do you need a licence or registration? — Securities and Futures Commission (SFC) · current page
  3. Selling of Investment Products to Private Banking Customers — Hong Kong Monetary Authority (HKMA) · 2012-06-12
  4. Hong Kong Schedule of Fees and Charges (Private Bank) — Standard Chartered Bank (Hong Kong) Limited, Private Bank · 2026-07-01
  5. Hong Kong's single-family offices total surpasses 3,380 — Financial Services and the Treasury Bureau and InvestHK · 2026-02-10

Cite this page

You may quote this page freely; please keep the source and date. Suggested format:

Private Wealth Ecosystem Editorial (2026). “Private Banks, EAMs, Family Offices and Insurers Compared.” privatewealth.hk. https://privatewealth.hk/en/compare/ (accessed YYYY-MM-DD).