Circular 102 makes brokerages' capital buffers stronger after years of expanding into riskier, less liquid assets: expert

Circular 102 regulations, which aim to raise safety levels for high-risk activities at securities firms in Vietnam, are almost equivalent to Basel II standards, said Nguyen The Minh, head of retail research and development at Yuanta Securities Vietnam.

“They are designed to make securities companies' capital buffers stronger after years of expanding into riskier, less liquid assets,” he told The Investor.

The Ministry of Finance recently issued Circular No. 102/2025/TT-BTC, tightening capital safety and risk governance standards for securities firms in an effort to strengthen the resilience and sustainability of the country’s stock market.

The circular, signed by Minister of Finance Nguyen Van Thang on October 29, 2025, amends and supplements several provisions of Circular No. 91/2020/TT-BTC and will come into force on December 15, 2025.

Under the revised rules, proprietary investments will be subject to additional risk-weighted adjustments based on their size relative to equity capital. Investments accounting for 10-15% of a firm’s equity will face a 10% risk premium, rising to 20% for 15-25%, and 30% for holdings exceeding 20%.

For the first time, the circular also introduces a market risk factor for corporate bonds with credit ratings. Bonds issued by entities rated below BBB by international agencies such as S&P, Fitch, or Moody’s, or those without ratings, will incur an additional 10% risk weighting.

Non-core investments will also face higher risk coefficients. Deposits for real estate purchases will be assigned a 150% risk weight, while non-business-related lending or receivables will carry the same level of risk.

Minh said small and mid-sized brokerages holding “non-rated” or low-quality corporate bonds would be most affected.

Another expert, Khuc Ngoc Tuyen, said the new rules would push firms with weaker capital adequacy to strengthen risk management and restructure balance sheets, as riskier assets can no longer be treated as safe.

“The rules effectively penalize concentrated proprietary portfolios, forcing firms to diversify and reduce exposure to market volatility,” Tuyen said, adding that larger, well-capitalized firms with robust governance are unlikely to be significantly impacted.

On financial forums, many investors have expressed concerns that Circular 102 would tighten the regulation on the margin lending-to-equity ratio from 200% to 180%.

However, in an interview with The Investor, Nguyen The Minh, head of analysis at Yuanta Securities Vietnam, said that the “margin lending-to-equity ratio” and the “capital adequacy ratio” are different indicators.

“At present, the regulation on margin lending balance has not changed and remains at a maximum of twice the company’s equity. Meanwhile, the regulation on available capital to total risk capital, according to the financial safety ratio formula in Circular 102, must be greater than 180% and remains the same as in the previous Circular 91.”

Similarly, Khuc Ngoc Tuyen, head of sales at SSI Securities, said that the 180% figure in Circular 102 is completely unrelated to the margin lending ratio for investors. The 180% represents the capital adequacy ratio (CAR), calculated by the formula: available capital ratio = company’s own capital/total risks the company bears. This is an indicator that measures the internal financial health of the securities company itself.

In addition, Tuyen emphasized that, contrary to market concerns, Circular 102 does not contain any provisions changing the margin lending ratio that investors are allowed to borrow. This ratio continues to be governed by other regulations (such as Decision 87 of the State Securities Commission).