Are the Outsourcing Guidelines applicable to intra-group outsourcing for fund management companies?
last revised 12 October 2021
Yes. All financial institutions including FMCs are expected to retain ownership and responsibility over the outsourced functions, regardless of whether the function has been outsourced to external service providers or intra-group.
FMCs that are part of a group can leverage on group-wide risk control and governance functions, such as the group internal audit function, to aid in their assessment of the areas outsourced to head office or related companies. For example, if trade execution and/or risk management functions are outsourced to head office, the FMC can rely on the work of centralised internal auditors in the group that cover the trade execution desk and/or risk management functions. The FMC is not expected to commission a separate audit on these outsourced functions.