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Responsible Officer papers · Last updated October 2026

HKSI LE Paper 4: Regulation of Credit Rating Services: free practice test

The regulation paper for Responsible Officers of Type 10, providing credit rating services, taken with Papers 1, 7 and 10. It covers the SFO licensing framework for credit rating agencies, ongoing compliance obligations, the SFC Code of Conduct for Persons Providing Credit Rating Services, and market misconduct.

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About the Paper 4 exam

The regulation paper for Responsible Officers of Type 10, providing credit rating services, taken with Papers 1, 7 and 10. It covers the SFO licensing framework for credit rating agencies, ongoing compliance obligations, the SFC Code of Conduct for Persons Providing Credit Rating Services, and market misconduct.

What's on the exam

Paper 4
Regulatory Framework and Licensing
6 key facts
Operational Compliance
6 key facts
CRA Code of Conduct
6 key facts
Market Misconduct
6 key facts

Each branch is a topic in the official outline. Members see every key fact on the full mind map. Read the free study guide →

How to pass the Paper 4 exam

  • 40 questions in 60 minutes is 90 seconds each, which is comfortable if you know the material.
  • You need 70% to pass: 28 out of 40, so you can only afford to miss 12.
  • The CRA Code follows the IOSCO Code of Conduct Fundamentals: know its main themes, namely quality and integrity of the rating process, independence and conflicts of interest, and responsibilities to the investing public and issuers.
  • For misconduct, keep Part XIII (Market Misconduct Tribunal, civil) and Part XIV (criminal prosecution) of the SFO straight: same conduct, different tribunals and different consequences.

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Create a free account after the test: your score by topic, a mistakes bank, the complete study notes for the first topic, flashcards and the HKSI Key Numbers Sheet.

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What's in the premium Paper 4 prep

Premium Paper 4 prep is studied one topic at a time. Each step starts with that topic's key notes and flashcard deck, then its own question sets of 25, so you master one topic before you move to the next. When every topic is strong, the 6 full mock exams show you're ready.

3,000practice questions, every answer explained
6full-length mock exams, 50 questions each, timed
800flashcards with spaced repetition, sorted by topic
60comprehensive key notes across 4 topics

Your step-by-step study path

  1. 1
    Regulatory Framework and Licensing15 key notes, 200 flashcards, then 750 practice questions in 30 sets of 25
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  2. 2
    Operational Compliance15 key notes, 200 flashcards, then 750 practice questions in 30 sets of 25
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  3. 3
    CRA Code of Conduct15 key notes, 200 flashcards, then 750 practice questions in 30 sets of 25
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  4. 4
    Market Misconduct15 key notes, 200 flashcards, then 750 practice questions in 30 sets of 25
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  5. Final step: 6 full mock exams50 questions each, timed like test day. Pass them, then book your exam.
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Read the complete Paper 4 study notes for “Regulatory Framework and Licensing”

Our first full set of comprehensive notes, about 10 minutes of reading: What credit rating services are · The regulatory framework and the SFC · Who does what · Personal data · Anti-money laundering and counter-financing of terrorism · Discipline and governance, a worked exam example, the traps examiners use and a one-minute recap. Create a free account to read it and see how premium notes work before you decide.

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3,000 practice questions

3,000 exam-style questions per exam, organized topic by topic in sets of 25. Every answer explained, with the rule it comes from.

6 full mock exams

6 full-length timed mock exams per exam, with real question counts and time limits, so test day feels like practice day.

Exam Readiness Score

One 0 to 100 number that tells you when you're ready to book. Reach 80 and you're covered by our Pass Guarantee.

800 flashcards + spaced repetition

800 flashcards per exam, in a deck for each topic, that come back right before you'd forget them. Five minutes a day keeps every number fresh.

60 comprehensive key notes

60 key notes per exam, split across its topics and each explained in full: the concepts, worked exam examples, the traps examiners use and a quick recap. Your first set is free with an account.

Mind maps

See the whole exam on one screen: every topic and the facts under it.

Sample questions with answers

These are the questions in the free test above, with answers. Try the test first. You'll learn more by getting some wrong.

1. Providing credit rating services is which type of regulated activity under the Securities and Futures Ordinance?
Answer: Type 10. Type 10 regulated activity under Schedule 5 to the SFO is providing credit rating services. Type 9 is asset management and Type 6 is advising on corporate finance.
2. Under Schedule 5 to the SFO, providing credit rating services means preparing credit ratings for the purpose of:
Answer: Dissemination to the public or distribution by subscription. Schedule 5 defines providing credit rating services as preparing credit ratings for dissemination to the public or distribution by subscription, whether in Hong Kong or elsewhere.
3. A bank asks a licensed CRA to rate a bond issue purely for the bank's own internal credit decisions, with no distribution to any other users. Under the SFO, this activity is:
Answer: Not a regulated activity, because the rating is not disseminated to the public or distributed by subscription. Type 10 covers ratings prepared for dissemination to the public or distribution by subscription. A rating prepared privately for one client's own internal use falls outside that definition.
4. The SFC Code of Conduct for Persons Providing Credit Rating Services is largely based on which international standard?
Answer: The IOSCO Code of Conduct Fundamentals for Credit Rating Agencies. The SFC's CRA Code adopts the IOSCO Code of Conduct Fundamentals for Credit Rating Agencies, adapted for Hong Kong licensed corporations.
5. Which of these changes must a licensed corporation notify to the SFC?
Answer: A change of any address it uses for its regulated business. The licensing rules require licensed corporations to notify the SFC of changes to prescribed particulars, including the addresses used for carrying on regulated business, within the set time.
6. Under the Personal Data (Privacy) Ordinance, a CRA collecting client information must collect it:
Answer: By lawful and fair means and only for a lawful purpose directly related to its functions. Data Protection Principle 1 of the PDPO (Cap. 486) requires personal data to be collected by lawful and fair means for lawful purposes directly related to the data user's functions.
7. A CRA analyst suspects a transaction may involve money laundering. Under Hong Kong's AML regime, the correct action is:
Answer: File a suspicious transaction report with the Joint Financial Intelligence Unit and not tip off the client. Suspicions of money laundering or terrorist financing are reported to the JFIU under the Organized and Serious Crimes Ordinance (s.25A) and related ordinances, and the firm must not tell the client that a report has been made (tipping off).
8. Under the Securities and Futures (Keeping of Records) Rules, records of a licensed CRA's business dealings must generally be kept for:
Answer: At least 7 years. The Keeping of Records Rules require most records of a licensed corporation's business to be kept for at least 7 years.
9. A licensed corporation's financial year ends on 31 December. Under the Accounts and Audit Rules, its audited accounts and auditor's report must be submitted to the SFC within:
Answer: 4 months after the year end. The Securities and Futures (Accounts and Audit) Rules require a licensed corporation to submit its audited accounts and auditor's report to the SFC within 4 months after the end of its financial year.
10. The SFC's capital rules for licensed corporations, including CRAs, are set out in:
Answer: The Securities and Futures (Financial Resources) Rules. The Financial Resources Rules (FRR) under the SFO set minimum liquid capital and paid-up capital requirements for licensed corporations, including those carrying on Type 10 activity.
11. Under the CRA Code, each credit rating agency should:
Answer: Adopt and publish its own code of conduct and adhere to it. Following the IOSCO Code, the CRA Code expects a CRA to adopt, publish and adhere to its own code of conduct, showing how it implements the principles.
12. A CRA rates a structured finance product whose underlying assets were originated by the CRA's parent bank. Under the CRA Code, the CRA should:
Answer: Manage the conflict, for example by disclosure and removing conflicted analysts from the process. The CRA Code requires CRAs to identify and manage conflicts of interest, including through disclosure, separation of roles and removal of conflicted personnel from the rating process.
13. Under the CRA Code, a CRA's rating methodology should be:
Answer: Rigorous, systematic and publicly disclosed in sufficient detail. The CRA Code requires rating methodologies to be rigorous, systematic, documented and publicly disclosed so users can understand the basis of ratings.
14. Under the SFO, civil market misconduct proceedings are heard by the:
Answer: Market Misconduct Tribunal. Part XIII of the SFO gives the SFC power to bring civil proceedings for market misconduct before the Market Misconduct Tribunal; Part XIV covers criminal prosecution in court.
15. A CRA analyst learns confidentially that a rated issuer is about to announce a profit warning, and tells a friend who sells the issuer's shares. This conduct most likely constitutes:
Answer: Insider dealing. Insider dealing under Part XIII/XIV of the SFO means dealing in listed securities while in possession of inside information. CRAs often handle price-sensitive information, so this is a key risk area.

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Paper 4 exam FAQ

How many questions are on the Paper 4 exam?

40 multiple-choice questions, with a time limit of 60 minutes. Format: closed book, computer-based.

What is the passing score for Paper 4?

70%.

How much does the Paper 4 exam cost?

HK$2,000 in Hong Kong (HK$2,450 at overseas Prometric centres). Fees change, so confirm with the HKSI Institute before you enrol.

Which languages is the Paper 4 exam offered in?

English or Traditional Chinese.

Where do I take the Paper 4 exam?

HKSI Institute computer-based test centre in Hong Kong, or Prometric centres outside Hong Kong.

Is this Paper 4 practice test free?

Yes. The 15-question practice test on this page is free, with an explanation for every answer and no signup. A free account also unlocks the complete study notes for the first topic. The full Paper 4 prep is Premium at HK$1,147 a month for this exam.

What's in the premium Paper 4 prep?

3,000 practice questions organized topic by topic (Regulatory Framework and Licensing: 750; Operational Compliance: 750; CRA Code of Conduct: 750; Market Misconduct: 750), 6 full-length timed mock exams of 50 questions, 800 flashcards and 60 comprehensive key notes split across all 4 topics, plus a mistakes bank and the Readiness Score.

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Exam details are summarized from the official candidate information available in October 2026. HKSI Institute changes formats and fees, so confirm with Hong Kong Securities and Investment Institute (HKSI Institute) before you book. HKSIMock is not affiliated with the HKSI Institute or the SFC.

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