In March 2016, the Financial Services Development Council (FSDC) of Hong Kong published a paper to examine whether the financial market of Hong Kong should introduce regulatory framework to promote equity crowdfunding. This article examines the recent experiences of the United States and United Kingdom in setting a regulatory framework on equity crowdfunding and seeks to identify what Hong Kong can learn from its Anglo-American counterparts in regulating such activity. It is ultimately argued that these experiences provide a good platform for implementing a broadly similar regime in Hong Kong by permitting crowdfunding within the scope of current regulated activities.
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