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Johnny Xie, CPAResearch Analyst What’s Happened On May 22, the China Securities Regulatory Commission (CSRC) announced it hadissued Notices of Investigation and Administrative Penalty Pre-Notification Lettersto three online brokers—Futu, Tiger, and Long Bridge. The investigations concern Concurrently, the CSRC, in conjunction with eight other departments, released the'Implementation Plan for Comprehensive Rectification of Illegal Cross-BorderSecurities, Futures, and Fund Business Activities.' This plan (or new rules ) outlines Companies Responses Laterthat evening,Futu and Tiger both confirmed receipt of regulatorynotifications forpenalties totaling RMB308.1mn and RMB1.85bn, respectively,with personal fines also issued to their CEOs. Tiger has accepted its penalty andcommitted to full cooperation and rectification. Futu, highlighted that its penalty isa proposal and will cooperate with regulators, having already implemented DB’s view While further hearings and penalty negotiations are pending,we believe theprimary long-term concern for online brokers regarding potential penalties forillegal cross-border activities has been largely alleviated. This resolution shouldsupport valuation normalization, despiteanticipated downward revisions torevenue and earnings trajectoriesdue to reduced mainland client contribution. 25 May 2026Other Financial Services The new regulations implement a two-year transition to progressively halt tradingservices for existing Mainland investors when they are physically onshore.Conversely, trading activities are unaffected when these individuals are personally Ourdistressed analysisshows that Futu's revenue could decrease by 8% (FY26) and 16% (FY27), with PAT falling by 24% (FY26) and 23% (FY27). Tiger would seea more pronounced impact, with revenue decreasing by 10% (FY26) and 20%(FY27), and PAT dropping by 52% (FY26) and 50% (FY27). Further detailed guidelines for sector-wide practices in servicing mainland clientsare also anticipated, uncertainties surrounding these details may still cause some Summary of CSRC Penalties and Mainland ClientContribution Impact Key impacts for outstanding mainlander clients New regulations introduce a two-year transition period to gradually cease tradingservices for existing Mainland investors when they are physically located onshore. Longer and wider impact: Cross-Border Regulations will Expand ScopeBeyond Online Brokers The new requirements are designed to standardize cross-border practices forserving existing mainland clients andwill be imposed on a broader industry scope,encompassing Chinese domestic and foreign securities firms and banks. Whiledetailed regulatory rules and a specific timetable have not yet been fully clarified, Assessing the impact to Futu and Tiger’s business andfinancials We anticipate a negative impact, though not severe, on both companies' revenueforecast due to the new regulations affecting their AUM growth and tradingactivities. However, the severity should be contained because: (1) a two-yeartransition period has been granted, and (2) regulators do not demand the closure ofall existing mainland accounts by the end of this period, but rather require all In a worst-case scenario—which appears unlikely given that regulators have notmandated such an outcome—where all outstanding mainland accounts are closedwithin two years (50% by end-2026, and the remainder by end-2027), and clientsonly liquidate assets without further purchases, Futu and Tiger's financials wouldface significant headwinds. Assuming full payment of proposed penalties in 2026, As a result, downward earnings revisions for both companies are anticipated.While the full impact awaits more detailed regulatory guidance,we foresee their Figure 4: Distressed scenario analysis impact to FY26 -27 Appendix 1 Important Disclosures *Other information available upon request *Prices are current as of the end of the previous trading session unless otherwise indicated and are sourced from local exchanges via Reuters, Bloomberg and other vendors . Otherinformation is sourced from Deutsche Bank, subject companies, and other sources. For disclosures pertaining to recommendations or estimates made on securities other than the primarysubject of this research, please see the most recently published company report or visit our global disclosure look-up page on our website at https://research.db.com/Research/Disclosures/EquityResearchDisclosures. Aside from within this report, important risk and conflict disclosures can also be found at https://research.db.com/Research/Disclosures/Disclaimer. Investors Analyst Certification The views expressed in this report accurately reflect the personal views of the undersigned lead analyst about the subjectissuers and the securities of those issuers. In addition, the undersigned lead analyst has not and will not receive anycompensation for providing a specific recommendation or view in this report. Johnny Xie. Equity Rat