# Private Banks, EAMs, Family Offices and Insurers Compared

> A side-by-side comparison of the four roles in Hong Kong's private wealth ecosystem—where assets are held, who decides, licences and supervisors, thresholds, fee sources, conflict locations and exit—plus the three service models and four client classifications.

- URL: https://privatewealth.hk/en/compare/
- Author: Private Wealth Ecosystem Editorial (https://privatewealth.hk/about/)
- Reviewed by: Private Wealth Ecosystem Editorial Editorial Board
- Published: 2026-11-04
- Updated: 2026-11-04
- Language: en

## Key takeaways

- The decisive differences between the four roles are who holds the assets and who decides: a private bank holds and may decide, an EAM only decides, a family office decides for the family, and an insurer neither holds custodied assets nor decides for the client.
- Supervisors follow legal status: HKMA for banks (with SFC rules), SFC for EAMs, generally no licence for a single family office, the Insurance Authority for insurers.
- Fee sources map to conflict locations: custody, commissions, margin and rebates at the bank; management fees and custodian retrocessions at the EAM; family-borne costs at the family office; embedded charges and bonus spread at the insurer.
- The roles stack rather than substitute: bank custody plus bank or EAM management plus family office decisions plus policies as the long-term layer.

## 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

- Asset and Wealth Management Activities Survey 2024 — Securities and Futures Commission (SFC) 2025-07 https://www.sfc.hk/-/media/EN/files/COM/Reports-and-surveys/EN_AWMAS-2024.pdf
- Do you need a licence or registration? — Securities and Futures Commission (SFC) current page https://www.sfc.hk/en/Regulatory-functions/Intermediaries/Licensing/Do-you-need-a-licence-or-registration
- Selling of Investment Products to Private Banking Customers — Hong Kong Monetary Authority (HKMA) 2012-06-12 https://brdr.hkma.gov.hk/eng/doc-ldg/docId/20120612-1-EN
- Hong Kong Schedule of Fees and Charges (Private Bank) — Standard Chartered Bank (Hong Kong) Limited, Private Bank 2026-07-01 https://www.sc.com/en/uploads/sites/66/content/docs/pvb-hk-schedule-of-fees-and-charges-en.pdf
- Hong Kong's single-family offices total surpasses 3,380 — Financial Services and the Treasury Bureau and InvestHK 2026-02-10 https://www.investhk.gov.hk/en/news/hong-kongs-single-family-offices-total-surpasses-3-380-injecting-over-10-billion-annually-into-local-economy/

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