Japanese

3. Registration Screening Procedure and Registration Requirements

(1) Overview of registration screening procedure and registration application documents

1) Flow of registration screening procedure

The outline of the procedure for screening of registration of a Financial Instruments Business is generally as described below. Since the contact point for the specifics of registration differs depending on whether the procedure for registration is handled in English or Japanese, please see the applicable flowchart. Regarding the eligibility requirements for an applicant to be subject to all-in-English registration procedures, please see “2) Contact with Financial Services Agency/Local Finance Bureau or Local Finance Office” below.
Please note that, to smoothly complete the procedure from prior consultation to registration, the registration applicant should determine in an early stage (i) the specific business description and methods, (ii) personnel structure, and (iii) internal control system.

（See 2)  below） （See 3) below） （See 4) below）
（See 5) below）

（See 2) below） （See 3) below） （See 4) below）
（See 5) below）

2) Contact with Financial Services Agency/Local Finance Bureau or Local Finance Office

< Consultation before commencement of registration screening procedure >
　The Financial Market Entry Office, which was established jointly by the FSA and the Local Finance Bureaus, seamlessly provides all-in-English one-stop services for pre-application consultation, registration procedures, and supervision for foreign asset management firms newly entering the Japanese market. Please refer to (i) and (ii) below for the eligibility requirements for an applicant to be subject to all-in-English registration procedures and post-registration supervision by the Financial Market Entry Office. 
　Even while a foreign financial business operator may not meet the eligibility requirements prescribed in (i) and (ii), the Financial Market Entry Office accepts requests for consultations from all types of foreign financial business operators, including asset management firms, pertaining to: pre-application legal interpretation (regulatory applicability screening/assessment) in preparation for business registration as a financial instruments business operator; viability of their business models/schemes under Japanese applicable laws and regulations; as well as inquiries regarding this Guidebook. Inquiries are accepted both in Japanese and English.
　The Financial Market Entry Office, as a single point of contact to ensure an integrated one-team approach for foreign financial business operators who are considering establishing a business base in Japan, responds to a wide range of inquiries/consultation requests in regard to regulatory procedures for establishing a business base in Japan under applicable financial laws and regulations.
 

 

 

Financial Market Entry Office	103-0026
		7th Floor, FinGATE TERRACE, 8-1 Nihonbashi-kabuto-cho, Chuo-ku, Tokyo	E-mail: marketentry@fsa.go.jp Phone: +81-3-6667-0551

< Contact with Local Finance Bureau/Local Finance Office >
　If an applicant does not fall into the category of either of the above (i) or (ii) (cf. p. 50), the applicant will be referred to the contact point for the specifics of registration at the competent authority (e.g. the competent Local Finance Bureau and/or Local Finance Office) which has the jurisdiction over the registered domicile of the applicant's head office. (The Financial Market Entry Office will accept requests for pre-application consultations on legal interpretation (regulatory applicability assessment/screening) and on business scheme/model viability.)
　Before preparing a Summary of Registration Applicant, an applicant who wishes to be registered as a financial instruments business operator shall contact the competent Local Finance Bureau and/or Local Finance Office that has the jurisdiction over the registered domicile of the applicant's head office (if you are a foreign business operator who wishes to register as an Investment Advisory and Agency Business Operator without a business office in Japan, contact Kanto Local Finance Bureau).
　For specific contact points of each local finance bureau/local finance office, please refer to “Contacts at Local Finance Bureaus/Local Finance Offices”.

< Collaboration with the relevant local authorities >
Depending on the nature of the inquiry, the FSA may collaborate with the relevant local governments and others to offer holistic assistance, by ensuring an integrated one-team approach for foreign asset management companies and others newly entering the Japanese market. Please refer to the following for information on key relevant local governments and others.
 

 

3) Prior consultations

• The purpose of a prior consultation is to confirm the registration applicants’ planned business scheme including its organizational structures, and examine in advance their compliance with laws/regulations and Guidelines for Supervision, as well as the information entered in documents to be submitted.
• In a prior consultation, in general, the registration applicant explains its business schemes including organizational structures, and, as necessary, more specific details are confirmed in interviews and by other methods. In interviews, the registration applicant may use reference documents (e.g. company overview, business scheme diagram and organization chart) for explanation. To confirm the matters required under laws and regulations or the Guidelines for Supervision, the registration applicant should also prepare a “Summary of Registration Applicant ” or other document, based on which details will be confirmed.
• Registration applicants for registration of Financial Instruments Business are asked to prepare a “Summary of Registration Applicant ” during the period of prior consultation, with the aim of facilitating smooth dialogue in confirming legal requirements and viewpoints shown in the Guidelines for Supervision. The “Summary of Registration Applicant ” should be prepared upon consultation with the Financial Market Entry Office or the competent local finance bureau/local finance office. So if you are to apply for registration, contact the relevant office before preparing a summary.
• In prior consultation, matters listed below, for example, will be confirmed, though they may differ depending on the type of registration and registration applicant’s business schemes.

• After confirmation of the necessary information, the registration applicant prepares drafts of application documents (including attachments) based on which the matters required to be specified and contents of attachments will be confirmed.
• The average period for prior consultation is three to four months, though it may largely differ depending on the scale or complexity of business schemes and various other circumstances. Please note that, if the business scheme changes, additional time for reconfirmation will be required.

 

4) Registration application (submission of application forms)

• Upon completion of the confirmation of required matters in prior consultation, the registration applicant prepares and submits the application documents. Along with the application, payment of 150,000 yen as registration and license tax is required.  Please note that the tax should be paid to the tax office with jurisdiction over the location of each local finance bureau. (Contact the Financial Market Entry Office or  the relevant finance bureau to find out which tax office you should pay.)

 

• The registration application form should be submitted along with various attachment documents. Major attachments are as follows:

< Major attachments >

Documents to be attached	Juridical person	Individual (Type II Financial Instruments Business, Investment Advisory and Agency Business Only)	Remarks	Related articles
Affidavit of the registration applicant	○	○		Article 29-2(2)(i) of the Act
Document describing the business and business methods	○	○	For matters to be specified, see Article 8 of the FIB Cabinet Office Ordinance. Refer also to VI-3-1-1 (2) of the Guidelines for Supervision for Investment Management Business and VI-3-1-2 (4) of the Guidelines for Supervision for Investment Management Business for Qualified Investors.	Article 29-2(2)(ii) of the Act, Article 8 of FIB Cabinet Office Order
Documents describing the business execution systems such as personnel structure and organization structure relating to the business	○	○	For matters to be specified, refer to VI-3-1-1 (3) of the Guidelines for Supervision for Investment Management Business and VI-3-1-2 (5) of the Guidelines for Supervision for Investment Management Business for Qualified Investors.	Article 29-2(2)(ii) of the Act, Article 9(i) of FIB Cabinet Office Order
Resumes of officers and important employees	○	―	If an officer of the registration applicant is a juridical person, the background of such juridical person officer.	Article 29-2(2)(ii) of the Act, Article 9(ii)(a) of FIB Cabinet Office Order
Extracts of the certificates of residence of officers and important employees	○	―	Or equivalent document (affidavit or similar document), if the individual is a foreigner, or does not reside in Japan. If the officer of the registration applicant is a juridical person, certificate of registered matters or any equivalent document (affidavit or similar document)	Article 29-2(2)(ii) of the Act, Article 9(ii)(b) of FIB Cabinet Office Order
Certificate that officers and important employees are not bankrupt	○	－	To be issued by the municipality of their registered domicile. Or equivalent document (affidavit or similar document) in the case of foreigners.	Article 29-2(2)(ii) of the Act, Article 9(ii)(d) of FIB Cabinet Office Order
Affidavits of officers and important employees	○	－		Article 29-2(2)(ii) of the Act, Article 9(ii)(e) of FIB Cabinet Office Order
Resumes of the registration applicant and important employees	―	○		Article 29-2(2)(ii) of the Act, Article 9(iii)(a) of the FIB Cabinet Office Order
Extracts of certificates of residence of the registration applicant and important employees	―	○	Or equivalent document (affidavit or similar document), if the individual is a foreigner, or does not reside in Japan.	Article 29-2(2)(ii) of the Act, Article 9(iii)(b) of FIB Cabinet Office Order
Certificate that the applicant and important employees are not bankrupt	―	○	To be issued by the municipality of their registered domicile. Or equivalent document (affidavit or similar document) in the case of foreigners.	Article 29-2(2)(ii) of the Act, Article 9(iii)(d) of FIB Cabinet Office Order
Affidavits of important employees	―	○		Article 29-2(2)(ii) of the Act, Article 9(iii)(e) of FIB Cabinet Office Order
Document describing the status of persons with specified relationships (parent company, etc., subsidiaries, etc., and holding companies)	○	○	Including associated companies (Article 177(6) of  FIB Cabinet Office Ordinance ) in the case of Type I Financial Instruments Business.	Article 29-2(2)(ii) of the Act, Article 9(iv) of FIB Cabinet Office Order
Internal rules concerning financial instruments business	○ (Except Investment Advisory and Agency Business)	―		Article 29-2(2)(ii) of the Act, Article 9(v) of FIB Cabinet Office Order
Document evidencing that the registration applicant does not fall under the criteria provided in Article 13 (iv) of FIB Cabinet Office Ordinance	〇 (Type II Financial Instruments Business only)	〇 (Type II Financial Instruments Business only)	Required to be submitted only in the case of conducting a Business of Transaction, etc. of Beneficial Interest in Real Property Trust . See section 3 (2) 2) (v) (a).	Article 29-2(2)(ii) of the Act, Article 9(vii) of FIB Cabinet Office Order
Document describing the ability to carry out  the Specified Investment Management Business Related to Real Property	〇 (Investment Management Business only)	―	Required to be submitted only in the case of conducting a Specified Investment Management Business Related to Real Property. See section 3 (2) 2) (v) (b).	Article 29-2(2)(ii) of the Act, Article 9(viii) of FIB Cabinet Office Order
Documents describing the overview of the crypto assets and financial indicator	〇 (Except Investment Advisory and Agency Business)	〇 (Type II Financial Instruments Business only)	Required to be submitted only in the case of conducting a Derivative Transaction pertaining to crypto assets or a financial indicator related to a crypto asset (see Article 8(xii) of the FIB Cabinet Office Order). *Derivative Transactions related to crypto assets fall under the category of OTC Transactions of Derivatives, etc. for the time being, and it is necessary to be registered as a Type I Financial Instruments Business Operator.	Article 29-2(2)(ii) of the Act, Article 9(x) of FIB Cabinet Office Order
Articles of incorporation	〇	―		Article 29-2(2)(iii) of the Act
Certificate of registered matters	〇	―	Or equivalent documents (which certify the location of the head office and places of business in Japan, and its officers) if the registration applicant is a foreign juridical person who is to register only for Investment Advisory and Agency Business and will not establish an office in Japan.	Article 29-2(2)(iii) of the Act
Final balance sheet (including related footnotes) and income statement (including related footnotes)	〇	―		Article 29-2(2)(iii) of the Act, Article 10(1)(i) of FIB Cabinet Office Order
Document describing the calculated net assets	〇 (Type I Financial Instruments Business and Investment Management Business only)	―		Article 29-2(2)(iii) of the Act, Article 10(1)(ii)(a) of FIB Cabinet Office Order
Document describing the Major Shareholders’ trade name or individual name,, and the locations of their head offices or principal offices (in cases where a Major Shareholder is an individual, the domicile or residence), as well as the number of the Subject Voting Rights held by the Major Shareholders	〇 (Type I Financial Instruments Business and Investment Management Business only)	―	If the registration applicant is a foreign juridical person, including a document certifying that confirmation by the relevant foreign regulatory authority has been made regard to the persons equivalent to Major Shareholders, or any equivalent document	Article 29-2(2)(iii) of the Act, Article 10(1)(ii)(b) and (c) of FIB Cabinet Office Order
Document evidencing that the registration applicant is a person conducting the same type of business as Type I Financial Instruments Business in a foreign country in accordance with the laws and regulations of the said country (including a case where the person holding all of its shares or equity in investment engages in the same type of business as Type I Financial Instruments Business)	〇 (Only in the case of Type I Financial Instruments Business and when the registration applicant is a foreign juridical person)	―		Article 29-2(2)(iii) of the Act, Article 10(1)(iii)(a) of FIB Cabinet Office Order
Document describing the calculated capital adequacy ratio	〇 (Type I Financial Instruments Business only)	―		Article 29-2(2)(iii) of the Act, Article 10(1)(iii)(b) of FIB Cabinet Office Order
Receipt for payment of registration and license tax	〇	〇

 

• In a case where the eligibility requirements prescribed in (i) and (ii) are not met, basically, registration application filings shall be  prepared in Japanese. For any document that cannot be prepared in Japanese due to special circumstances, the Japanese translation thereof should be attached. That being said, if such documents are articles of incorporation or minutes of a shareholders’ meeting or a board of officers’ meeting that are prepared in English, a translation of the outline thereof is to be sufficient.
• Samples of the forms of registration application for Type II Financial Instruments Business and Investment Advisory and Agency Business, as well as the examples of a part of the attachments (Japanese only) are provided at the URLs below:

 

5)　Joining a self-regulatory organization 

• Types of self-regulatory organizations (Financial Instruments Firms Associations)

　Self-regulatory organizations related to Financial Instruments Businesses in Japan (Financial Instruments Firms Associations) (hereinafter, “Association(s)”) and a rough scope of businesses of each Association are as provided below. (For the specific scope of applicable businesses and membership qualifications, please refer to the website of each Association or contact the Association directly.)

Japan Securities Dealers Association	Type I Financial Instruments Business
Japan Investment Advisers Association	Investment Management Business (discretionary investment business and fund management business), Investment Advisory and Agency Business
The Investment Trusts Association, Japan	Investment Management Business (investment corporation asset management business and investment trust management business)
Type II Financial Instruments Firms Association	Type II Financial Instruments Business
The Financial Futures Association of Japan	Currency-related derivatives transactions and other certain derivative transactions

 

• Membership of an Association

　Membership of an Association is not mandatory.  However, if a Financial Instruments Business Operator does not join one, except in the case of conducting only Investment Advisory and Agency Business, it is necessary for it to have in place internal rules that have contents equivalent to the articles of incorporation or other rules of the Association and to establish an internal system for compliance with those internal rules (Article 29-4(1)(iv)(d) of the Act). And therefore, explanation of the status of establishment of such internal rules and internal system and submission of supporting documents will be required in the registration screening procedure.  At present, Financial Instruments Business Operators conducting Type I Financial Instruments Business or Investment Management Business basically have membership to their applicable Associations.

• ADR measures

　Financial Instruments Business Operators are required to implement designated complaint processing and dispute resolution measures (ADR measures) before starting business operations (Article 37-7 of the Act). At present, to conduct Type I Financial Instruments Business, ADR measures using the Financial Instruments Mediation Assistance Center (FINMAC), a Designated Dispute Resolution Organization, should be implemented. FINMAC are also available for other types of Financial Instruments Business Operators by joining their applicable Association. In addition, Type II Financial Instruments Business Operators may use FINMAC as their ADR measures without having a membership to the Type II Financial Instruments Firms Association by making an individual user registration with FINMAC. Although FINMAC is not available for Investment Management Business Operators and Investment Advisory and Agency Business Operators that do not have membership with an Association, they can take other complaint processing and dispute resolution measures (see Article 37-7 of the Act, Article 115-2 of FIB Cabinet Office Ordinance). So check carefully in advance.

• Membership procedures

　Financial Instruments Business Operators are eligible for membership with an Association upon completion of the registration for the Financial Instruments Business Operator. Since the membership procedure takes a certain period of time, it is advisable to discuss with the relevant Association about the membership at the time of the prior consultation with the local financial bureau or local financial office. For details of the membership procedures of each Association, please see the website of each Association or directly contact the appropriate Association.

 

(2) Requirements for registration by type of Financial Instruments Business

 

1) Overview of registration requirements specified in the FIEA and the Guidelines for Supervision

< Registration requirements specified in the FIEA >

	Type I Financial Instruments Business	Type II Financial Instruments Business	Investment Management Business	Investment Management Business for Qualified Investors	Investment Advisory and Agency Business	Related articles
The registration applicant or its officers and important employees have not received any specified administrative penalty, punishment or other sanction in the past.	〇	〇	〇	〇	〇	Article 29-4(1)(i)(a) through (c) of the Act (ii) and (iii) of the same paragraph
Other businesses are not contrary to the public interest.	〇	〇	〇	〇	〇	Article 29-4(1)(i)(d) of the Act
Having a sufficient personnel structure to perform Financial Instruments Business in an appropriate manner *See “Requirements related to personnel structure and systems specified in the Guidelines for Supervision” below.	〇	〇	〇	〇	〇	Article 29-4(1)(i)(e) of the Act
Having the necessary system in place for performing Financial Instruments Business in an appropriate manner *See “Requirements related to personnel structure and systems specified in the Guidelines for Supervision” below.	〇	〇	〇	〇	〇	Article 29-4(1)(i)(f) of the Act
Capital	50 million yen	10 million yen	50 million yen	10 million yen	―	Article 29-4(1)(iv)(a) of the Act
Business office in Japan	〇	〇	〇	〇	―	Article 29-4(1)(iv)(b) of the Act
(In the case of a foreign judicial person) representative in Japan	〇	〇	〇	〇	―	Article 29-4(1)(iv)(c) of the Act
(If not joining an Association), preparation of internal rules that have contents equivalent to the articles of incorporation or other rules of the Association and establishment of an internal system in compliance therewith	〇	〇	〇	〇	―	Article 29-4(1)(iv)(d) of the Act
Legal form as a stock company (limited to one that has a board of directors and either a company auditor/auditors, an audit or supervisory committee or a nominating committee, etc.) or a judicial person of the same kind as a company with a board of directors established in compliance with foreign laws and regulations *In the case where a foreign juridical person seeks to engage in Type I Financial Instruments Business, it is also necessary to be a person that engages in the same kind of business as Type I Financial Instruments Business in a foreign country in compliance with the laws and regulations of said country (including a case where the person holding all of its shares or the equity in investment engages in the same kind of business as Type I Financial Instruments Business).	〇	―	〇	〇 (A board of directors is not required)	―	Article 29-4(1)(v)(a) of the Act
Net assets	50 million yen	―	50 million yen	10 million yen	―	Article 29-4(1)(v)(b) of the Act
No business that compromises investor protection due to difficulties in managing the risk of losses	〇	―	〇	〇	―	Article 29-4(1)(v)(c) of the Act
No non-qualified Major Shareholders	〇	―	〇	〇	―	Article 29-4(1)(v)(d) through (f) of the Act
Capital adequacy ratio	120％	―	―	―	―	Article 29-4(1)(vi)(a) of the Act
Not using a trade name that another Type I Financial Instruments Business Operator is already using or a trade name that could give rise to the misconception that it is another Financial Instruments Business Operator	〇	―	―	―	―	Article 29-4(1)(vi)(b) of the Act
Deposit	―	10 million yen (Limited to individuals)	―	―	5 million yen	Article 31-2 of the Act
Rights holders consist exclusively of Qualified Investors.	―	―	―	〇	―	Article 29-5(1)(i) of the Act
The total amount of investment assets is 20 billion yen or less.	―	―	―	〇	―	Article 29-5(1)(ii)

 
<Reference URL>  

< Requirements related to personnel structure and systems specified in the Guideline for Supervision >

	Type I Financial Instruments Business	Type II Financial Instruments Business	Investment management business	Investment management business for qualified investors	Investment advisory/agency business
Top managers	Top managers must be sufficiently qualified to conduct Financial Instruments Business in a fair and appropriate manner, in terms of their backgrounds and capabilities.	Same	Same	Same	Same
Managing directors	Managing directors must understand the viewpoints regarding governance indicated in the FIEA and various other laws and regulations, and have sufficient knowledge and experience to conduct governance, in addition to sufficient knowledge and experience regarding compliance and risk management to conduct Financial Instruments Business in a fair and appropriate manner.	Same	Same	Same	Same
Staff	The staff must include two or more permanent officers or employees with more than three years of experience regarding the relevant Type I Financial Instruments Business.	―	―	―	―
Persons in charge of asset management or investment advice.	―	―	Persons with sufficient knowledge and experience regarding investment assets must be secured for the position responsible for making asset investment on behalf of rights holders.	With regard to the position responsible for making asset investment on behalf of rights holders, whether at least one or two persons who fall under either of the following items have been secured as persons with sufficient knowledge and experience regarding investment assets. A.  A person who has been engaged in the business of providing advice or managing  the relevant assets for no less than one year B.  A person equivalent to A	Persons with sufficient knowledge and experience regarding the values of securities and financial instruments must be secured for the position of providing advice on investment decisions based on the analysis of the values of securities or financial instruments and other items.
Personnel structure of each division	The Financial Instruments Business Operator must be staffed and organized so that managers in charge of internal control are appropriately allocated, and personnel necessary for conducting relevant business in an appropriate manner are allocated to individual divisions. (Regarding the conduct of underwriting business in particular, it is necessary to ensure a sufficient control environment and secure staff to conduct the business in a fair and appropriate manner.)	The Financial Instruments Business Operator must be staffed and organized so that managers in charge of internal control are appropriately allocated, and personnel necessary for conducting relevant business in an appropriate manner are allocated to individual divisions.	Same as Type II Financial Instruments Business	Same as Type II Financial Instruments Business	The Financial Instruments Business Operator must be staffed and organized so that managers in charge of internal control and personnel necessary for conducting relevant business in an appropriate manner are appropriately allocated.
Staff in charge of compliance	The compliance division (staff in charge of compliance) must be independent from the sales division and staffed with personnel who have necessary knowledge and experience.	Same as Type I Financial Instruments Business	The compliance division (staff in charge of compliance) must be independent from the asset investment division and staffed with personnel with sufficient knowledge and experience.	With regard to establishment of an independent compliance division (staff in charge of compliance), whether at least one or two persons who fall under either of the following items have been secured as persons in charge of compliance (excluding cases where compliance work is outsourced). A.  A person who has been engaged in business related to guidance for ensuring compliance with laws and regulations with regard to the Financial Instruments Businesses for no less than one year B.  A person equivalent to A	Persons with sufficient knowledge and experience to be in charge of compliance must be secured.
Appointment of staff capable of setting up the internal structure for the relevant business	Staff capable of conducting the following processes should be secured, with regard to the relevant business: a. Compilation and      management of     account books,     reports and other     documents b. Disclosure c. Segregated     management of     customer assets d. Risk management e. Computer system     management f. Trading management,    customer management g. advertisement     screening h. Customer information     management i.  Processing of     complaints and     disputes j.  Internal audits	Staff capable of conducting the following processes should be secured, with regard to the relevant business: a. Compilation and     management of     account books,     reports and other     documents b. Disclosure c. Risk management d. Computer system     management e. Trading management,      customer management f. Advertisement    screening g. Customer information     management h. Processing of     complaints and     disputes i.  Internal audits	Staff capable of conducting the following processes should be secured, with regard to the relevant business: a. Compilation and     management of     account books,     reports and other     documents b. Disclosure c. Segregated     management of     investment assets d. Risk management e. Computer system     management f. Trading management    and customer    management by relevant    management divisions g. Management of     sensitive corporate     information h. Advertisement     screening i.  Customer information     management j.  Processing of complaints     and disputes k. Execution of asset      management business     by the investment     division l.  Internal audits m. Accounting and     screening related to     investment trust assets     in the case of     management of     investment trust assets	Whether at least one or two personnel needed for the same processes as Investment Management Business (excluding those not required for the relevant business to be conducted in an appropriate manner, considering the investment policy, the amount of assets managed and other circumstances of the Investment Management Business for Qualified Investors) have been secured. (In cases where arrangements and procedures for enabling proper compliance with laws and regulations are deemed to have been established, the same personnel as the staff in charge of compliance may be appointed.)	Staff capable of conducting the following processes should be secured, with regard to the relevant business: a. Compilation and     management of     account books,     reports and other     documents. b. Disclosure c. Risk management d. Computer system     management e. Customer     management f. Advertisement    screening g. Customer information     management h. Processing of     complaints and     disputes i.  Internal audits

2) Personnel requirements

The personnel and internal structure for each business operator will be determined on a case-by-case basis depending on the business model of each registration applicant. It is therefore impossible to set uniform standards, but please note the points below.

(i) Outsourcing of compliance operations

  As stated in the above (“Requirements related to personnel structure and systems specified in the Guidelines for Supervision,” the row of “Staff in charge of compliance”), a Financial Instruments Business Operator is required to have a compliance division/staff in charge, in principle. For Investment Management Business for Qualified Investors, however, points to be noted in outsourcing compliance operations are provided in the Guidelines for Supervision as follows (Guidelines for Supervision VI-2-7-1(2)). The following points are provided as general supervisory viewpoints, and additional examination may be required in view of the business operations of the Investment Management Business for Qualified Investors.

(ii) Independence of staff in charge of compliance

  In Type I Financial Instruments Business, Type II Financial Instruments Business, and Investment Management Business, division/staff in charge of compliance must be independent from sales division and asset management division, and staff members in charge of compliance are not allowed to concurrently serve for such divisions. See Guideline for Supervision IV-4-1(2)1) E, V-3-1(1)1)D, VI-3-1-1(1)1)D.

(iii) Separation of division for making investment decisions from division for taking orders
(iv) Actual examples          ● Business description