Futu’s US clearing company sits at the centre of a cross-border omnibus network

A US clearing broker inside Futu Holdings has become the balance-sheet hub for a cross-border network of Moomoo and Futu entities spanning Hong Kong, the United States, Singapore, Australia and Japan. Futu Clearing Inc.’s 2025 audited statements identify five affiliate omnibus or customer-account relationships that generated $56.62 million of clearing-fee revenue in total. The same notes disclose multibillion-dollar margin debits and almost $898 million of selected customer-related payable and credit balances carried through the US company.[1]

The structure matters because the consumer brand and the legal custodian are not always in the same country. A Moomoo customer may deal with a locally licensed broker, while securities, cash or financing positions are aggregated into an omnibus account at Futu Clearing in the United States. The audited note makes those relationships visible firm by firm. It does not show the identity of underlying customers, and the balances should not be described as deposits owned by Futu Clearing.[1][3]

Hong Kong generated four-fifths of disclosed affiliate clearing fees

Futu Securities International (Hong Kong) was the largest relationship. It used Futu Clearing to custody and clear trades through a customer account and borrowed through a margin loan secured by securities. Futu Clearing earned $44.69 million of clearing fees from the Hong Kong affiliate in 2025—78.94% of the $56.62 million total calculated across the five named affiliates. At year-end, the Hong Kong omnibus account had a $3.506 billion margin debit and a $626.07 million related-party customer payable balance arising in part from SEC customer-protection accounting.[1]

The year-on-year movement is striking. The same Hong Kong relationship generated $29.73 million of clearing-fee revenue in 2024, so the 2025 figure rose by $14.97 million, or 50.36%. Its margin debit decreased from $3.734 billion to $3.506 billion, a fall of 6.12%, while the disclosed related-party customer payable balance increased from $295.69 million to $626.07 million, or 111.73%. Those movements do not have to travel together because fees, debit financing and regulatory gross-up payables measure different aspects of the account.[1][2]

The audited note says the payable reflects a requirement under SEC Rule 15c3-3 to gross up certain credit items associated with the Hong Kong customer account. That wording is important. The $626.07 million is not described as ordinary corporate borrowing or revenue. It is included in payables to customers and proprietary accounts of broker-dealers in Futu Clearing’s statement of financial condition. Calling it a cash pile available to the parent would misstate both ownership and regulatory treatment.[1]

The US, Singapore, Australia and Japan network

Moomoo Financial Inc., the US introducing broker, clears customer transactions through Futu Clearing in an omnibus account for the exclusive benefit of its customers. Futu Clearing earned $1.63 million of clearing-fee revenue from that affiliate in 2025 and also earned payment for order flow on its transactions. At year-end the account had a $214.57 million free-credit balance and a $14.05 million short-credit balance included in customer and broker-dealer payables.[1]

Moomoo Financial Singapore used Futu Clearing as custodian and clearing broker for customer cash and securities on an omnibus basis. That relationship generated $7.24 million of clearing fees and carried a $247.42 million margin debit plus a $38.47 million short-credit balance at year-end. Futu Securities Australia generated $822,945 of fees. Moomoo Securities Japan generated $2.23 million and had a $4.47 million free-credit balance. Fees from the four non-Hong Kong affiliates totalled $11.92 million.[1]

Adding the specifically disclosed Hong Kong payable, US free and short credits, Singapore short credit and Japan free credit produces $897.63 million. That calculation is useful for showing the scale of selected credit-side balances but is not a consolidated customer-assets figure. It omits securities, margin debits and other accounts, and it combines items with different legal and accounting descriptions. The article therefore presents the components as a reconstruction of intercompany clearing relationships, not as a customer-protection ratio.[1]

One US entity links multiple local regulatory regimes

Futu Holdings’ annual report maps the licensing layer around the accounts. Moomoo Financial Inc. is a US introducing broker; Futu Clearing is a US broker-dealer and DTCC member with clearing capacity; Moomoo Financial Singapore holds a capital-markets services licence; the Australian entity holds an Australian financial services licence; and Futu Securities operates under Hong Kong regulation. The parent says customers experience the trading process as seamless even where the group uses different execution, settlement or clearing arrangements.[3]

Seamlessness for the user can obscure concentration behind the interface. Operationally, multiple local front ends depend on Futu Clearing’s books, systems, financing, custody and relationships with US market infrastructure. An incident at the clearing layer could therefore affect more than one branded market, even though local entities retain their own regulatory duties. The public records do not establish that such an incident is likely; they establish that the dependency exists.[1][3]

The structure also creates related-party pricing and governance questions. Every named counterparty is an affiliate. Clearing fees paid by one group entity are revenue to another, while margin financing, expense-sharing and payment-for-order-flow arrangements can move economics within the consolidated group. At group level many intercompany items are eliminated, but the regulated clearing entity must still manage credit exposure, liquidity and customer-protection calculations on its own books.[1][3]

The fee growth cannot be reduced to one balance-sheet ratio

The Hong Kong clearing fee rose 50.36% even as the year-end margin debit fell 6.12%. That divergence is evidence that the annual fee is not a simple fixed percentage of the closing loan balance. It can reflect trade volumes, settlement activity, custody services, pricing schedules and the path of balances through the year. Dividing $44.69 million of annual fees by the $3.506 billion year-end debit would produce a superficially precise percentage with no disclosed economic meaning because the numerator covers a year and the denominator is one day.[1][2]

The payable increase has a similar limitation. A higher Rule 15c3-3-related payable can reflect more credit items subject to gross presentation without proving that underlying customer cash doubled on a like-for-like basis. The 2025 note says the balance is related to the Hong Kong customer account and is included in customer and broker-dealer payables, while the margin debit is an amount owed to Futu Clearing. Presenting the debit and payable net would erase the regulatory gross-up the audited statements are designed to show.[1][2]

This distinction is especially important in an omnibus model. Futu Clearing sees the affiliate account, while the local broker maintains the underlying customer ledger and relationship. The clearing company’s audited statement can therefore show one large receivable, debit or payable where the consumer-facing entity records many individual positions. A regulator evaluating recoverability and customer protection needs both levels: the carrying broker’s aggregate exposure and the local entity’s allocation to beneficial customers.[1][3]

The network is also product-specific. Futu’s annual report says the group self-clears and settles certain securities markets and uses third-party clearing brokers for others. The audited Futu Clearing note concerns US clearing and custody relationships; it should not be read as proof that every trade in every country passes through the US company. The material finding is narrower: several local affiliates route at least part of their US-market customer business through the same regulated clearing entity.[1][3]

Capital disclosures show substantial headroom, but on different bases

Futu Holdings reported that Futu Clearing had HK$8.819 billion of net capital at 31 December 2025 against a HK$875.68 million requirement, leaving HK$7.944 billion of excess. Moomoo Financial had HK$423.59 million against a HK$71.67 million requirement. The parent table places those US entities alongside regulated subsidiaries in Hong Kong, Singapore and Malaysia, but the applicable rules differ by jurisdiction and the figures should not be converted into a single group capital ratio.[3]

A later CFTC return adds another regulatory lens. At 31 August 2026, Futu Clearing reported $1.241 billion of adjusted net capital against a $119.78 million requirement, while Moomoo Financial reported $127.33 million against $7.77 million. Together that was about $1.368 billion of adjusted net capital. The CFTC figures use US futures-commission-merchant definitions and a different date from the SEC and parent-company statements, so the apparent alignment should not be treated as an audited currency reconciliation.[3][4]

The risk is dependency, not evidence of missing assets

Nothing in the filings establishes that customer assets were missing, that safeguarding rules were breached or that the omnibus model is improper. Omnibus clearing is common because it can centralise settlement, financing and custody while a local broker maintains customer records. The investigative contribution is to connect disclosures normally read in isolation: an American clearing company earned most of its affiliate fee revenue from Hong Kong, carried accounts for four other markets and held the capital supporting a network presented to customers as locally accessible.[1][2][3][4]

The model concentrates three kinds of exposure. Credit exposure arises from margin debits and affiliate obligations. Operational exposure arises because several markets depend on one clearing platform. Regulatory exposure arises because customer-protection, capital and books-and-records duties sit across several regimes. A local customer’s legal claim remains against the relevant entity and under the relevant terms; the existence of a US omnibus account does not automatically import US securities-account protection into every jurisdiction.[1][3]

What customers and regulators should be able to see

More complete disclosure would identify the proportion of each local broker’s customer assets custodied through Futu Clearing, collateral and concentration limits for affiliate margin loans, liquidity arrangements for a rapid withdrawal or market shock, and the recovery plan if the US clearing platform were unavailable. It would also separate customer free credits, short-sale credits, house balances and regulatory gross-up items in a consistent cross-entity table. The audited note provides enough to reveal the network, but not enough to stress-test it.[1][3]

The central finding is that Futu Clearing is not merely a back-office subsidiary for one US app. It is a cross-border financial utility inside the group, linking customer and affiliate positions from at least five markets and generating $56.62 million of disclosed affiliate clearing fees in 2025. Understanding Moomoo’s international expansion therefore requires following the omnibus account and the regulated balance sheet behind the interface, not only the licence displayed to the customer.[1][3][4]

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