PrepLicense: HK Insurance · Study Notes

IIQE Paper V — Investment-linked Long Term Insurance Study Notes

Key revision notes for IIQE Paper V (Investment-linked Long Term Insurance). 132 topics across 5 parts, covering core concepts, legal principles, ordinances and practical knowledge.

Part 1: Introduction to ILAS

Paper V — Investment-linked Long Term Insurance · Part 1: Introduction to ILAS

Definitions and Concepts
  • An Investment-linked Assurance Scheme (ILAS) is an insurance product that combines life insurance protection with an investment component.
  • The policy value fluctuates according to the performance of the selected underlying funds, not a fixed return.
  • The policyholder bears the investment risk and the principal is not guaranteed.
  • ILAS policy value is directly linked to the market performance of the underlying investment funds, carrying investment risk.
  • Traditional life insurance (guaranteed or with-profits) typically offers more predictable returns not directly linked to funds.
  • Both policy types provide life insurance protection, but differ in their return mechanisms.
Definitions and Concepts
  • An Investment-linked Assurance Scheme (ILAS) is an insurance product that combines life insurance protection and investment functions. Part of the premium paid by the policyholder is used to purchase life insurance coverage, and part is invested in funds chosen by the policyholder, linking the policy's returns to the market performance of the chosen funds.
  • ILAS has both insurance and investment attributes, but returns on the investment portion are not guaranteed; the investment risk is borne by the policyholder.
Entry Age and Policy Term
  • Entry age and policy term are set by each ILAS product individually; there is no uniform cap.
  • Not all ILAS policies are whole-of-life; some are fixed-term.
  • ILAS is designed as a long-term investment tool. A longer premium payment term helps investors accumulate wealth through regular premium investment (dollar-cost averaging) and fully benefit from compounding. Stable premium income also helps insurers plan their investments.
  • Additionally, the declining surrender charge structure encourages policyholders to maintain long-term premium commitment to avoid incurring significant charges from early surrender.
Investment Component vs Protection Component
  • ILAS premium is first invested in linked funds at the premium allocation rate, forming the investment component.
  • The insurer funds the protection component by deducting cost of insurance and other charges from the unit account.
  • Hence the two components share the same premium and jointly affect the number of units available and overall policy value.
  • In ILAS, the cost of the protection component (such as critical illness coverage, life assurance charges, etc.) is typically paid by periodically redeeming fund units from the policy account, known as 'insurance charge deductions'.
  • This mechanism means that protection costs are deducted directly from the investment account, reducing funds available for investment and potentially affecting long-term investment returns. Protection charges typically increase with the insured's age.
  • (i) is correct: fund choice and investment risk rest with the policy holder. (ii) is correct: the death benefit is paid by the insurer under the policy terms.
Premium Allocation
  • (1) Correct: allocation rates are typically less than 100%.
  • (2) Correct: the first-year rate is often the lowest and rises in later years.
  • (3) Correct: unallocated portions cover commission, administration and underwriting costs.
  • The premium allocation rate is the percentage of each premium payment that, after deducting front-end charges, is actually used to purchase investment fund units. For example, an allocation rate of 100% means all premiums go to investment, while 85% means 15% goes to charges.
  • The allocation rate may be lower in the early years of the policy (e.g., 70-80%) and then increase to 100% or higher, 'rewarding' policyholders for long-term commitment.
  • First-year total premium = 5,000 x 12 = HK$60,000.
Features of ILAS Products
  • The policy value of ILAS is not fixed but directly linked to the performance of selected investment funds. When funds perform well, the policy value rises; when funds underperform, the policy value may fall, and the policyholder bears the investment risk.
  • Traditional life insurance typically offers fixed guaranteed returns or bonuses, and policyholders do not directly bear market investment risk.
  • ILAS policyholders must bear multiple risks: (1) Market risk — the investment performance of selected funds can rise or fall, and policy value may decline; (2) Credit risk of the insurer — if the insurer becomes insolvent, compensation may be affected; (3) Liquidity risk — some underlying funds may have low trading volume, making immediate redemption difficult during adverse market conditions, which affects the flexibility of surrendering or switching funds.
  • Before purchasing ILAS, investors should fully understand and assess all relevant risks to ensure the product suits their risk tolerance.
  • ILAS is a unitised product whose policy value equals units held multiplied by the fund NAV, with no guaranteed return.
  • Fund switching is normally allowed under stated conditions and death benefit structures vary by product design.
Basic Structure of ILAS
  • The subaccount is the core structure of an ILAS policy. Premiums paid by the policyholder (after deducting relevant charges) are used to purchase units of selected investment funds, which are held in the subaccount.
  • The value of the subaccount fluctuates with the market price of the fund units held, directly reflecting investment performance.
  • ILAS is a hybrid product combining life insurance protection with a unitised investment in funds within a single policy.
  • Premiums are used both to pay the cost of insurance and to purchase units of investment choices, with the policy value moving with the fund NAV.
Charges and Fees
  • The bid-ask spread is the difference between the offer price (at which fund units are purchased) and the bid price (at which they are sold). Investors buy at the higher offer price but sell at the lower bid price, and the spread constitutes an implicit cost.
  • A typical bid-ask spread is around 5%, meaning if an investor sells immediately after buying, they would lose approximately 5%.
Surrender Charges
  • Surrender charges in ILAS are typically highest in the early years of the policy and gradually decrease as the holding period increases, encouraging policyholders to hold long-term. Some policies reduce surrender charges to zero after a certain period (e.g., 10 to 15 years).
  • Surrender charges exist to compensate the insurer for administrative and commission costs incurred in the early stages of the policy.
Death Benefits
  • The death benefit of most ILAS policies is the higher of the policy account value and the basic sum assured (or a percentage of premiums paid), ensuring beneficiaries receive a minimum level of protection in all circumstances.
  • This design ensures that even if poor investment performance causes the account value to fall below the basic sum assured, beneficiaries still receive the agreed minimum benefit.
  • The death benefit is the higher of total premiums paid (HK$300,000) and the account value (HK$260,000).
  • The insurer therefore pays HK$300,000, with the shortfall covered by the insurance protection component.
Management Fees
  • Fund management charges are typically calculated as a percentage of the fund's net asset value (e.g. 0.5% to 1% per annum) and are periodically deducted from fund assets, directly reducing the unit NAV and the investor's actual return.
  • Even if fund performance is flat, the deduction of management fees will erode policy value over time; investors need positive returns to offset these charges.
ILAS vs Traditional Life Insurance
  • One of the main advantages of ILAS is greater charge transparency; policy documents must list all charges, allowing policyholders to clearly understand the cost structure. Additionally, ILAS typically offers multiple fund choices, allowing policyholders to switch funds based on market conditions and personal risk tolerance.
  • ILAS does not offer guaranteed returns; investment risk is entirely borne by the policyholder, which is one of its main disadvantages compared to traditional life insurance.
  • Under a traditional whole-life policy, the insurer bears the investment risk for guaranteed cash values and bonuses, whereas the policy value of an ILAS fluctuates with the chosen funds and the investment risk is borne mainly by the policy holder.
  • ILAS is regulated by the IA, not the MPFA, and still pays a death benefit.
Cooling-Off Period
  • The cooling-off period for ILAS policies in Hong Kong is 21 days, starting from the date the policyholder receives the policy documents or the Cooling-off Notice, whichever is earlier. During this period, policyholders can cancel the policy unconditionally.
  • Upon cancellation, policyholders receive a refund of premiums paid, less any investment losses due to market value adjustment. Under GL29, no deduction for administrative charges or commissions is permitted.
  • The cooling-off period runs for 21 calendar days from the signing of the application or receipt of the cooling-off notice, whichever is earlier. Here the earlier date is the signing date (1 April), and by industry practice the starting day itself is excluded from the count.
  • Counting 21 calendar days starting from 2 April (the day after signing) gives 22 April as the final day, so written notice to cancel must reach the insurer on or before 22 April.
Regulatory Framework for ILAS
  • ILAS is a life insurance product, so sales activities and insurers are supervised by the Insurance Authority.
  • Because ILAS also involves a collective investment scheme, the product and offering documents must be authorised by the SFC.
Product Key Facts Statement (KFS)

The SFC and IA require a KFS to accompany every ILAS at point of sale, highlighting fees, investment risk, surrender charges and the cooling-off period.

Suitability Assessment
  • Suitability requires matching investment horizon, liquidity needs and risk tolerance; a 25-year high-risk ILAS clearly does not fit a three-year drawdown goal and low risk appetite.
  • Signing a disclaimer cannot replace the suitability obligation under the ILAS code of conduct.
Disclosure Requirements
  • ILAS offers no guaranteed return; claiming it will always outperform a time deposit is misleading and breaches the fair-disclosure principle of the code.
  • Providing the KFS, disclosing commission, and using a compliant illustration document are all acceptable.
Policy Illustration Documents
  • The illustration must show projected policy values under different investment return assumptions and reflect the cumulative impact of all charges, including surrender charges.
  • An intermediary's personal sales forecast is not a required disclosure item and must not be used to compare products.

Part 2: Investments

Paper V — Investment-linked Long Term Insurance · Part 2: Investments

Meaning of Investment Risk
  • Investment risk refers to the variability between actual and expected returns, i.e., the uncertainty of returns.
  • Risk does not necessarily mean loss; it also includes the possibility of returns exceeding expectations.
  • The goal of risk management is to achieve the best possible return within an acceptable level of risk.
Categories of Risk
  • Systematic risk (also called market risk) affects the entire market and cannot be eliminated through diversification.
  • A global financial crisis is a systematic risk that impacts all asset classes.
Risk-Return Trade-off
  • The risk-return trade-off is a fundamental investment principle: higher potential returns are generally associated with higher risk.
  • High risk does not guarantee high returns, but seeking higher returns usually requires accepting greater uncertainty.
  • Investors should choose a portfolio appropriate to their risk tolerance.
  • The risk-return trade-off is a fundamental principle; promising risk-free high returns would amount to misrepresentation and mis-selling, breaching the Insurance Ordinance and Code of Conduct.
  • A licensed intermediary should correct the misunderstanding honestly and recommend products that match the client's suitability assessment to protect the client's interest.
Risk Reduction Techniques
  • Diversification spreads capital across different assets, regions, and sectors so that poor performance of any single investment has less impact on the overall portfolio.
  • Diversification can reduce unsystematic risk but cannot eliminate systematic risk.
  • 'Don't put all your eggs in one basket' is the fundamental concept of diversification.
Investment Considerations
  • Macroeconomic factors include interest rates, inflation, GDP growth, and exchange rates, which affect the overall financial market.
  • Changes in interest rates affect bond prices, corporate borrowing costs, and stock valuations.
Investment Objectives and Risk Tolerance
  • Know Your Client (KYC) is the foundation for providing appropriate investment advice.
  • Insurance intermediaries must understand the client's investment objectives, risk tolerance, investment horizon, and financial situation.
  • This helps ensure that recommended products are suitable for the client's needs.
Risk
  • The fundamental risk-return relationship is: investors must take on higher risk to expect higher returns as compensation; conversely, low-risk investments typically only offer lower expected returns.
  • This principle is fundamental to investment decision-making. Investors should choose an appropriate portfolio based on their own risk tolerance rather than simply pursuing high returns.
  • Diversification is the most effective method for reducing unsystematic risk. Spreading funds across different asset classes (such as equities, bonds, real estate), different sectors and different regions reduces the impact of any single investment failure on the overall portfolio.
  • Diversification is most effective when different investments are not perfectly positively correlated, effectively reducing the overall portfolio volatility.
Investment Considerations
  • When setting investment objectives, multiple factors need to be considered: desired investment return (e.g., capital appreciation or regular income), the level of risk one can accept (risk tolerance), the investment horizon (short-term or long-term), and the need for liquidity (when funds will be needed).
  • Balancing these factors helps formulate an appropriate investment strategy, ensuring the investment plan aligns with personal financial goals and life circumstances.
  • Macroeconomic factors are broad economic forces affecting the overall financial market, including: interest rates and monetary policy (determined by central banks), inflation rate, GDP growth, employment data, government fiscal policy and international trade conditions.
  • These macro factors have a significant impact on equity markets, bond markets and exchange rates; investors and analysts need to closely monitor changes in macroeconomic indicators.
Time Value of Money
  • Time value of money reflects the opportunity cost of investing money today and earning a return.
  • The concept applies to all financial assets, not only bonds.
  • Even if interest rates are near zero, inflation can still erode purchasing power.
  • The future value formula is: FV = PV × (1 + r)^n, where PV is present value, r is interest rate, and n is number of years.
  • Substituting values: FV = 1,000 × (1 + 0.05)^2 = 1,000 × 1.1025 = HK$1,102.50. This illustrates the compounding effect — interest in the second year is calculated on both the principal and the first year's interest.
  • The time value of money means a dollar held today is worth more than the same amount in the future, because it can be invested immediately to earn a return.
Compound Interest Calculation
  • Future value = 100,000 × (1.06)^3 = 100,000 × 1.191016 ≈ HK$119,100.
  • Dollar-Cost Averaging involves investing a fixed amount at regular intervals. When market prices are low, the fixed amount buys more units; when prices are high, it buys fewer units. Over the long term, this approach helps lower the average cost per unit and reduces market timing risk.
  • This method does not guarantee the lowest purchase price and cannot eliminate market risk, but it avoids poor decisions caused by attempting to 'time the market'.
  • The compound interest formula is FV = PV × (1+r)^n. Substituting PV = 10,000, r = 0.05, n = 2 gives FV = 10,000 × 1.05² = 10,000 × 1.1025 = HK$11,025.
  • Simple interest would yield only HK$11,000; the difference reflects the 'interest on interest' effect of compounding.
Present Value and Future Value
  • Present value = 10,000 / (1.05)^3 = 10,000 / 1.157625 ≈ HK$8,638.
  • The present value formula is PV = FV ÷ (1+r)^n. With FV = 1,100, r = 0.10, n = 1, PV = 1,100 ÷ 1.10 = HK$1,000.
  • Present value reflects today's worth of a future amount at the discount rate; the higher the discount rate, the lower the present value.
Diversification
  • Diversification effectively reduces unsystematic risk specific to individual companies or industries.
  • Systematic risk is market-wide and cannot be fully eliminated through diversification.
  • Inflation and FX risks need to be hedged through other instruments.
  • Unsystematic risk refers to risks specific to a company or industry, such as management scandals, strikes, or industry downturns, which are not directly related to the overall market. By holding uncorrelated assets, such risk can be diversified away.
  • Systematic risk (market risk) affects the entire market, such as interest rate changes, inflation, and economic recession, and cannot be eliminated through diversification; it can only be managed through tools such as hedging.
  • Diversification spreads exposure across multiple assets so that company- or sector-specific risks (unsystematic risk) offset each other, reducing overall portfolio volatility.
Asset Allocation
  • Younger investors with long horizons and higher risk tolerance should tilt toward growth assets.
  • Strategic asset allocation sets target proportions for each asset class based on the investor's long-term financial objectives, risk tolerance, and investment horizon, with periodic rebalancing to these proportions.
  • Tactical asset allocation involves temporarily adjusting asset class proportions from the strategic allocation based on short-term market forecasts or opportunities, aiming to generate additional short-term returns.
  • Traditional investment wisdom suggests that as investors age and approach their retirement goal, they should gradually reduce the overall risk of their portfolio by increasing the proportion of fixed income assets (e.g., bonds) and reducing high-volatility assets such as equities.
  • This is because older investors have a shorter investment horizon and insufficient time to wait for markets to recover from downturns, necessitating more stable assets. A common rule of thumb is 'equity proportion = 100 minus age'.
  • Asset allocation is a core portfolio management strategy that distributes funds across asset classes such as equities, bonds, cash and alternatives based on investor objectives, horizon and risk tolerance.
Risk Tolerance
  • Age, horizon, financial situation and investment knowledge are core factors in assessing risk tolerance.
  • (4) The most recent travel destination has no direct bearing on risk tolerance.
  • Common factors in assessing investment risk tolerance include: investment horizon (longer horizon allows more tolerance for short-term volatility), financial situation (income, assets, liabilities), investment knowledge and experience, psychological tolerance for losses, and investment objectives.
  • Although religious beliefs may influence a client's ethical investment preferences (e.g., avoiding certain industries), they are not a core factor in assessing risk tolerance.
  • An investor close to retirement seeking capital preservation and stable income is typically conservative to balanced, with a core of lower-volatility investment-grade bonds and money market instruments, plus a measured allocation to blue-chip equities for inflation protection.
  • Suitability principles require the intermediary to clearly explain the mismatch, warn of the risks, and keep written records and client acknowledgement in line with regulatory and internal requirements when product risk exceeds the client's tolerance.
Efficient Market Hypothesis
  • Semi-strong EMH holds that public information is instantly reflected in prices.
  • The Efficient Market Hypothesis has three forms: (1) Weak form — prices reflect all historical price information; technical analysis is ineffective; (2) Semi-strong form — prices reflect all publicly available information (including financial reports, news, etc.); fundamental analysis also cannot generate consistent excess returns; (3) Strong form — prices reflect all information (including insider information); no analysis can generate excess returns.
  • Under this view, the long-run alpha potential of technical and fundamental analysis is questioned, though insider information may still generate excess returns.
Inflation
  • Real return ≈ nominal rate − inflation = 1% − 3% = −2%.
  • When inflation exceeds nominal interest, purchasing power declines.
  • Ms Wong's real purchasing power falls by about 2% per year.
  • Fixed-rate bonds provide a fixed coupon rate. When inflation rises, the real purchasing power of the fixed interest declines (real return = nominal return - inflation rate). If the inflation rate exceeds the coupon rate, the real return may even be negative.
  • Furthermore, rising inflation typically leads to higher market interest rates, which have an inverse relationship with bond prices, causing the market value of existing fixed-rate bonds to fall. Investors who sell before maturity will incur capital losses.
  • The real return is approximately the nominal return minus inflation: 4% − 5% = −1%.
Economic Cycle
  • In a recession, investors favour defensive assets; demand for government bonds and defensive equities rises.
  • Cyclical, highly leveraged and emerging-market assets typically underperform.
  • Therefore B is the most appropriate choice.
  • During recession, consumer spending declines and corporate earnings contract; cyclical stocks and commodity prices typically fall sharply. Investors tend to shift toward defensive assets.
  • Government bonds perform relatively better because of their safety (low default risk) and because central banks tend to cut interest rates during recessions (which pushes bond prices higher). Defensive stocks (utilities, food, healthcare) are less affected by the economic cycle and have relatively stable earnings.
  • In a recession, investors typically rotate to safe-haven assets such as high-grade government bonds for capital preservation and steady coupon income.
Portfolio Theory
  • The efficient frontier comprises portfolios that optimise the risk-return trade-off via mean-variance optimisation.
  • MPT guarantees no specific return and does not eliminate risk.
  • Efficient portfolios typically include multiple asset classes.
  • The Efficient Frontier is a curve composed of all optimal portfolios that offer the highest expected return at a given risk level, or the lowest risk at a given return level. Portfolios below the Efficient Frontier are considered suboptimal.
  • Investors should select the most appropriate portfolio from the Efficient Frontier based on their own risk preferences.
  • Correlation coefficient ranges from -1 to +1. When two assets are perfectly negatively correlated (-1), one rises when the other falls, resulting in minimum portfolio volatility. Combining assets with low or negative correlation effectively diversifies risk and reduces overall portfolio volatility.
Interest Rate and Bond Price Relationship
  • Bond prices move inversely to market interest rates.
  • The longer the duration, the greater the price sensitivity to rate changes.
  • Bond prices and market interest rates have an inverse relationship. When market interest rates rise, newly issued bonds offer higher coupon rates; existing lower-rate bonds become relatively less attractive, and investors are willing to pay less, causing existing bond prices to fall.
  • This is a fundamental principle of fixed income investing. The longer a bond's duration, the more sensitive it is to interest rate changes — i.e., a larger price drop when interest rates rise.
  • Bond prices move inversely to market interest rates. When newly issued bonds carry higher coupons, existing lower-coupon bonds become less attractive and their prices fall until yields align with prevailing rates.
  • Bonds with longer duration are more price-sensitive to interest rate changes.
Risk and Return
  • Risk premium refers to the additional expected return that investors demand for accepting risk above the risk-free rate. For example, the expected return on stocks exceeds that on government bonds; the difference is the equity risk premium.
  • Risk premium reflects investors' attitudes toward risk. The higher the risk, the greater the compensation demanded (i.e., the risk premium). This is one of the core concepts of modern portfolio theory.
  • Standard deviation is a statistical measure of the volatility of investment returns, reflecting how dispersed returns are around the mean. A larger standard deviation means higher volatility of returns and greater risk; a smaller standard deviation means more stable returns and lower risk.
  • In investment analysis, standard deviation is one of the most commonly used quantitative tools for measuring investment risk, and is often used together with expected returns to compare the risk-return characteristics of different investments.
  • Systematic risk, also known as market risk or non-diversifiable risk, refers to risks that affect the entire market and cannot be eliminated through portfolio diversification. Examples include: the global financial crisis, significant interest rate changes, inflation shocks, and wars.
  • In contrast, unsystematic risk (diversifiable risk) is risk specific to a company or industry and can be reduced through diversification. Individual company bankruptcies and management issues are examples of unsystematic risk.
Active vs Passive Investment
  • Passive investment strategies, by replicating index performance (e.g., Hang Seng Index), typically charge lower management fees and reduce transaction costs. Extensive research shows that most actively managed funds fail to consistently outperform their benchmark indices over the long term (after fees).
  • The disadvantage of passive strategies is the inability to outperform the market; they can only replicate average market performance and will also decline during bear markets.
  • Passive investing aims to replicate the constituents and weights of an index to deliver index-like returns; common vehicles include index funds and exchange-traded funds (ETFs).
  • Because no active research or frequent trading is required, passive funds typically charge lower management fees and incur lower transaction costs than actively managed funds.
Macroeconomic Indicators
  • GDP (Gross Domestic Product) measures the total market value of all final goods and services produced in a country or region during a given period, and is the most important indicator of the overall scale and production performance of an economy.
  • CPI reflects inflation levels, unemployment rate reflects labour market conditions, and trade balance reflects import/export status. These are all important macroeconomic indicators, but none reflects overall economic output as comprehensively as GDP.
  • Gross Domestic Product (GDP) measures the total value of all final goods and services produced by an economy over a period and is the core gauge of overall economic size and growth.
Investment Objectives
  • The SMART principle is a framework for setting effective objectives: S=Specific, M=Measurable, A=Achievable, R=Relevant, T=Time-bound.
  • 'Time-bound' means the objective must have a specific completion deadline, for example 'accumulate HK$1 million in retirement savings within 5 years', rather than just 'save for retirement'. A clear time frame helps in developing a specific investment plan.
  • Capital appreciation refers to generating investment returns through increases in the market price of assets (such as stocks and real estate). Investors seeking capital appreciation typically accept higher short-term volatility risk in exchange for potential long-term high returns.
  • In contrast, investors seeking 'income' focus on regular cash flows such as dividends and interest, while investors seeking 'capital preservation' prioritise protecting principal and typically invest in low-risk assets.
  • Liquidity refers to the ability of an asset to be quickly converted to cash at close to its fair market value. Highly liquid assets (such as listed stocks and money market instruments) can be quickly realised at any time; low-liquidity assets (such as real estate and private equity) may take a longer time to sell and may require accepting a discount.
  • ILAS policies typically have lower liquidity, as surrender charges are high in the early years and some funds may be locked up. Investors should consider their liquidity needs when evaluating ILAS.

Part 3: Investment Assets

Paper V — Investment-linked Long Term Insurance · Part 3: Investment Assets

Money Market Instruments
  • Money market instruments are short-term debt instruments, typically with maturity of less than one year.
  • A Certificate of Deposit (CD) is a short-term deposit instrument issued by banks and is a money market instrument.
  • Money market instruments are short-term financial instruments with maturities typically within one year, primarily including: bank deposits (time deposits), negotiable certificates of deposit (NCDs), treasury bills and commercial paper.
  • Negotiable certificates of deposit are short-term time deposit notes issued by banks that can be transferred in the secondary market, representing a typical money market instrument.
  • Money market instruments are short-term, highly liquid and low credit risk, e.g. treasury bills and certificates of deposit.
  • They focus on capital preservation and liquidity, not capital appreciation.
Debt Securities
  • The coupon rate is the fixed annual interest rate set at bond issuance, calculated based on the bond's face value.
  • For example, a bond with face value $1,000 and coupon rate 5% pays $50 interest per year.
  • The coupon rate differs from market interest rates; changes in market rates affect the bond's market price.
  • Bond prices have an inverse relationship with market interest rates: when market rates rise, existing bond prices fall; when market rates fall, existing bond prices rise.
  • This is because when rates rise, newly issued bonds offer higher coupons, making existing lower-coupon bonds less attractive, so their prices must fall.
  • Long-term bonds are more sensitive (higher duration) to interest rate changes than short-term bonds.
Equities
  • A bonus issue involves capitalising retained earnings to issue new shares to existing shareholders for free.
  • After issuance, the number of shares increases and the share price is adjusted downward; the company's total market capitalisation remains unchanged.
  • The shareholder's ownership percentage is maintained, and the total market value does not immediately increase.
  • The Stock Exchange of Hong Kong (SEHK) is Hong Kong's primary stock exchange, a subsidiary of Hong Kong Exchanges and Clearing (HKEX).
  • Its primary function is to provide an orderly, fair, and efficient market for securities trading.
  • Regulating insurance companies is the responsibility of the Insurance Authority; interest rate policy is set by the Hong Kong Monetary Authority.
Financial Derivatives

Futures contracts require both buyer and seller to transact at the agreed price on the expiry date; both parties are obligated to fulfil the contract.

Investment Funds
  • Investors in a unit trust hold 'units', with each unit representing a proportional share of the fund's total assets.
  • Investors do not directly hold the individual stocks or bonds purchased by the fund.
  • The value of units (net asset value per unit) changes with the market value of the fund's underlying assets.
  • Open-end funds (e.g., unit trusts) can accept new subscriptions and redemptions at any time, with the fund size changing accordingly.
  • Closed-end funds issue a fixed number of shares; investors must buy and sell on the secondary market (e.g., stock exchange), and the fund size does not change due to trading.
  • The market price of closed-end funds may trade at a discount or premium to the net asset value (NAV).
Basic Concepts of Equities
  • Ordinary shareholders have voting rights at general meetings.
  • Ordinary shares do not pay fixed interest, are not redeemable, and rank behind creditors on liquidation.
  • The main rights of ordinary shareholders include: (1) Voting rights — to vote on important company matters at general meetings; (2) Right to dividend distribution — to receive dividends proportionately when the company is profitable and decides to pay dividends (not guaranteed); (3) Residual asset claim — after repaying all debts and preferred shares upon liquidation, ordinary shareholders have a claim on the residual assets.
  • Ordinary shareholders have the lowest priority in claims upon company liquidation, bearing the highest risk but potentially receiving the greatest rewards when the company is profitable.
  • The key feature of preferred shareholders is priority over ordinary shareholders for dividend payment and distribution of residual assets upon liquidation, although they typically have no or limited voting rights.
  • Preferred shareholders still rank behind all creditors and are not guaranteed any capital gain.
Dividends and Capital Gains
  • Capital gain = selling price minus purchase price = HK$24 minus HK$20 = HK$4.
  • The HK$1 dividend is dividend income and is not part of the capital gain.
  • Income-oriented investors value predictable cash flow; steady cash dividends from blue-chip companies suit them.
  • Growth and start-up shares emphasise capital gains and usually pay little or no dividend.
  • Dividend yield = Dividend per share ÷ Market price per share × 100%. It measures the annual dividend return that investors can receive by purchasing the stock at the current market price, and is an important indicator for assessing the income attractiveness of a stock.
  • For example, if a stock's market price is HK$40 and the dividend per share is HK$2, the dividend yield is 5%. A higher dividend yield indicates a higher dividend return relative to the market price, making the stock more attractive to income-seeking investors.
Equity Valuation Methods
  • P/E ratio equals share price divided by earnings per share.
  • A high ratio may indicate strong growth expectations or that the share is over-valued.
  • P/E ratio = Market price per share ÷ Earnings per share (EPS). It reflects how much investors are willing to pay for each dollar of company earnings, and is a commonly used equity valuation metric. A higher P/E suggests investors have higher expectations for future growth, but may also indicate overvaluation.
  • For example, if a stock's market price is HK$20 and EPS is HK$2, the P/E ratio is 10x, meaning investors pay HK$10 in market value for every HK$1 of earnings.
  • P/E ratio = Market price per share ÷ Earnings per share = $60 ÷ $4 = 15 times.
  • The P/E ratio reflects how much investors are willing to pay for each dollar of earnings and is a common relative valuation metric.
Yield and Duration
  • Bond prices move inversely to interest rates; when rates rise, existing fixed-coupon bonds become less attractive and prices fall.
  • The longer the duration, the more sensitive the bond price is to rate changes.
  • The longer the duration, the more sensitive the bond price is to interest rate changes.
  • Duration measures the weighted average maturity of cash flows and is unrelated to credit risk or coupon rate.
  • Duration measures a bond's price sensitivity to changes in market interest rates. The longer the duration, the greater the price fluctuation when market interest rates change. For example, a bond with a duration of 10 years will see its price fall by approximately 10% for every 1% rise in market interest rates.
  • Therefore, long-term bonds carry far greater interest rate risk than short-term bonds. In a rising interest rate environment, a portfolio holding long-duration bonds will face significant downward price pressure.
Credit Rating
  • S&P ratings of BBB− and above are investment grade; BB+ and below are non-investment grade (junk bonds).
  • Investment grade implies relatively low default risk.
  • Moody's credit ratings from highest to lowest are: Aaa, Aa, A, Baa (investment grade), Ba, B, Caa, Ca, C (speculative/junk grade). Baa3 is the lowest investment-grade rating, equivalent to 'BBB-' (S&P).
  • Bonds rated below Baa3 (i.e., Ba1 and below) are classified as 'speculative grade' or 'high-yield bonds' (commonly called 'junk bonds'), with higher default risk but typically offering higher interest rates as compensation.
  • An investment grade bond is one rated BBB- / Baa3 or above by major rating agencies (S&P, Moody's, Fitch), reflecting relatively low default risk.
  • Bonds rated below BBB- / Baa3 are non-investment grade or 'high-yield' (junk) bonds, carrying higher default risk and offering higher yields.
Types of Bonds
  • Zero-coupon bonds are issued at a discount and redeemed at face value at maturity; the return is the difference between purchase price and face value.
  • They pay no interim coupons and are highly sensitive to interest rate changes.
  • Exchange Fund Bills and Notes are issued by the HKMA on behalf of the HKSAR Government, denominated in HKD, and regarded as local government bonds with very low credit risk.
  • High-yield corporate bonds and emerging market sovereign bonds carry materially higher credit risk; convertible bonds have a different risk-return profile from government bonds.
Mutual Funds
  • Open-end funds issue and redeem units at the daily-calculated NAV; the number of units is not fixed.
  • Closed-end funds are exchange-listed with a fixed number of units.
  • Open-ended funds (such as most mutual funds) have a variable number of units; investors can subscribe for new units or redeem existing units at the fund's net asset value (NAV) at any time, and the fund size expands or contracts accordingly.
  • Closed-end funds (such as listed investment companies) issue a fixed number of units at their initial public offering (IPO) and are subsequently listed and traded on an exchange; their market price is subject to supply and demand and may be above or below NAV (trading at a premium or discount).
  • Mutual funds are managed by professional fund managers who pool investors' capital and invest across various assets according to the fund's objective to achieve diversification. Investors hold fund units bought and sold at NAV.
  • Mutual fund returns are not guaranteed; they depend on the market performance of the underlying assets and the principal may be lost.
Exchange-Traded Funds (ETFs)
  • ETFs typically track a specific index and trade on an exchange like a share, with prices fluctuating intra-day.
  • They are passive investments and usually have lower management fees than mutual funds.
  • Key advantages of ETFs: (1) Trading flexibility — can be bought and sold at market prices at any time during exchange trading hours, unlike traditional mutual funds which require waiting until end of day to transact at NAV; (2) Low costs — most ETFs are passively managed, tracking an index, with expense ratios typically far lower than actively managed funds; (3) High transparency — holdings are typically disclosed daily.
  • ETFs also face market risk; their value can rise or fall, with no guaranteed returns or government guarantees.
  • The defining feature of ETFs is that they are listed on exchanges and can be traded intraday at market prices, offering greater liquidity than traditional mutual funds which are typically priced once daily.
  • ETFs still charge management fees (usually lower), are regulated by bodies such as the SFC, and do not guarantee outperformance of the market.
Futures Contracts
  • Shorting futures profits when the index falls; if the index rises, the short side must close at a higher price and incurs a loss.
  • Futures are leveraged and losses can exceed the initial margin.
  • At expiry, futures contracts are settled by two main methods: (1) Physical delivery — both parties deliver actual goods or assets at the agreed price, common in commodity futures (e.g., gold, oil); (2) Cash settlement — no physical delivery; instead, cash is settled based on the difference between the market price at expiry and the contract price, common in stock index futures and some financial futures.
  • Most futures traders close out their positions (offset) before contract expiry and do not actually take physical delivery.
  • A long futures position commits the holder to buy the underlying at the contract price. If the settlement price at expiry is below the contract price, the long must pay the difference (multiplied by the contract multiplier), resulting in a loss.
Real Estate Investment Trusts (REITs)
  • REITs are exchange-traded collective investment schemes holding income-producing properties and must distribute most of their income.
  • They give investors property exposure without buying physical real estate.
  • REITs must distribute most of their distributable income (typically 90% or more) as dividends to investors, thereby providing relatively stable regular income. REITs are typically listed on exchanges, allowing investors to trade them like stocks, with higher liquidity than direct property ownership.
  • REITs invest across a wide range of property types, including commercial offices, shopping malls, industrial properties, and hotels. REITs in Hong Kong are regulated by the SFC.
  • A REIT is a collective investment vehicle that pools investors' funds to acquire and manage income-producing properties, and is required to distribute the majority of its rental income to unitholders as dividends — matching Mr Cheung's need for diversified commercial property exposure with rental income.
  • Convertible bonds, hedge funds and government bonds do not directly provide property rental income.
Hedge Funds
  • Hedge funds use flexible strategies including leverage, short-selling and derivatives, and carry higher risk.
  • In Hong Kong they are generally limited to professional investors and are not guaranteed products.
  • Key characteristics of hedge funds: (1) Strategy flexibility — can use leverage, short selling, derivatives, and other complex strategies, unrestricted by traditional mutual fund investment limits; (2) High fees — typically charge management fees (e.g., 2% per annum) plus performance fees (e.g., 20% of profits); (3) Limited audience — typically only open to institutional investors and high-net-worth individuals; (4) Less regulation — enjoy greater investment flexibility but lower transparency.
  • Hedge funds do not guarantee capital; investors may face substantial losses, making them unsuitable for ordinary retail investors.
  • Hedge funds are known for flexible strategies, using leverage, derivatives and short-selling to seek absolute returns; in Hong Kong they are mainly offered to professional investors rather than retail public.
  • Hedge fund disclosure and regulatory requirements are generally less stringent than those for retail mutual funds, not the same.
Structured Products
  • Structured products combine bonds and derivatives; their return depends on underlying assets such as shares, indices or exchange rates.
  • Investors are exposed to issuer credit risk and possible loss of principal.
  • The risk and return of structured products vary by design; some offer principal protection, others do not. Investors need to carefully understand product terms, including charges, credit risk (issuer risk), and liquidity risk.
  • ELNs are not principal-guaranteed, are not government bonds, and are not ETFs settled at NAV daily.
Private Equity
  • Private equity invests in unlisted companies with long lock-ups and low liquidity; it is an alternative investment.
  • It is generally limited to professional investors and is not exchange-listed.
  • Private equity (PE) invests in companies not listed on public markets, primarily through: venture capital (investing in early-stage startups), growth capital (investing in growth-stage companies), and leveraged buyouts (acquiring mature companies).
  • Characteristics of private equity: low liquidity (capital typically locked up for 5-10 years), high minimum investment threshold, low information transparency, but potentially higher returns than public markets. PE fund investors are typically institutional investors or high-net-worth individuals.
  • Private equity invests primarily in unlisted companies, creating value through long holding periods and active management. Lock-up periods are typically 7–10 years, liquidity is low, and risk is higher.
  • Private equity is not exchange-traded, carries no government guarantee, and its returns come mainly from capital gains rather than fixed interest.
Diversification
  • Diversification reduces non-systematic risk by spreading funds across different asset classes, regions or sectors.
  • Systematic (market) risk cannot be eliminated by diversification.
  • The core idea of diversification is to allocate funds across assets with lower correlation, thereby reducing unsystematic risk specific to individual companies or industries. Cross-industry and cross-regional diversification is generally more effective than diversifying within a single industry.
  • Diversification cannot eliminate systematic risk affecting the entire market (e.g. global financial crises, interest rate shocks); such risks must be managed through asset allocation or hedging strategies.
Asset Allocation
  • Aggressive clients have higher risk tolerance and allocate more to growth assets such as equities.
  • Conservative clients tilt toward bonds and money market instruments.
Derivatives
  • Derivatives derive their value from an underlying asset and may be used for hedging or speculation.
  • Leverage amplifies both gains and losses, so the risks are higher.
  • Derivatives can be used for: hedging (reducing existing risk), speculation (profiting from price movements), or arbitrage (profiting from price differences between different markets). Due to leverage, the risk of derivatives can be far greater than directly holding the underlying asset.
Fixed Income Securities
  • A normal yield curve slopes upward (positive slope), meaning rates are higher for longer maturities. This reflects: (1) Long-term investors bear greater uncertainty and liquidity risk, requiring higher return compensation; (2) Long-term inflation expectations are usually higher than short-term; (3) The market expects interest rates to rise in the future.
  • An inverted yield curve (short-term rates exceeding long-term rates) is generally considered a leading indicator of economic recession.
Collective Investment Schemes
  • In Hong Kong, collective investment schemes (such as mutual funds and unit trusts) must obtain authorisation from the Securities and Futures Commission (SFC) before they can be offered to the public. The SFC reviews the fund's investment policy, fee structure, fund manager qualifications, etc., to protect investor interests.
  • Funds available within ILAS policies are typically SFC-authorised funds. The IA is responsible for regulating ILAS policies themselves, while the MPFA oversees MPF schemes.
Interest Rate and Bond Price Relationship
  • Bond prices move inversely to market interest rates. When rates rise, newly issued bonds offer higher yields, making existing fixed-coupon bonds less attractive, so their prices fall — and vice versa.
  • All fixed-rate bonds (including zero-coupon and coupon-bearing bonds) are affected by interest rate movements, not only zero-coupon bonds.
Leverage Effect
  • Margin = $100,000 × 20% = $20,000. A 10% price rise produces a profit of $100,000 × 10% = $10,000. Return on margin = $10,000 ÷ $20,000 = 50%.
  • This illustrates the leverage effect: a 10% move in the underlying becomes a 50% return on margin at 5x leverage; losses are similarly magnified on the downside.

Part 4: Investment-linked LT Insurance Policies

Paper V — Investment-linked Long Term Insurance · Part 4: Investment-linked LT Insurance Policies

Historical Development
  • ILAS are insurance products primarily regulated by the Insurance Authority (IA).
  • Since ILAS involves an investment component, the Securities and Futures Commission (SFC) also has regulatory oversight over related intermediaries.
  • HKMA primarily regulates the banking sector; HKEX oversees exchanges and related markets.
Types of Charges
  • The policy administration charge is an administrative fee periodically (usually monthly) deducted from the policy value by the insurer.
  • This fee covers administrative expenses related to policy management.
  • The fee structure of ILAS is complex, including premium allocation charges, policy administration charges, mortality charges, fund management fees, and switching fees.
  • The mortality charge is deducted periodically from the policy value to pay for the cost of life insurance protection.
  • As the insured ages and mortality risk increases, the mortality charge typically increases accordingly.
  • This is an important cost factor in ILAS policies that policyholders need to understand.
Premium Structure
  • A single premium plan requires the policyholder to pay the entire premium in one lump sum at inception, with no further premiums required.
  • This type of plan suits investors with a large lump sum who wish to invest their funds immediately.
  • Unlike regular premium plans, single premium plans do not carry the risk of insufficient premiums or policy lapse.
  • A single premium plan requires the policyholder to pay the entire premium in one lump sum at the time of application, with no further regular premiums required.
  • Unlike regular premium plans, single premium plans are generally suitable for investors who have a large lump sum available for a one-time investment.
  • A premium holiday only suspends contributions; the insurer continues to deduct COI, administration and fund management fees.
Calculations
  • Partial withdrawal refers to the policyholder withdrawing a portion of funds from the policy value while the remaining balance continues to be invested and the policy remains in force.
  • Unlike a full surrender, a partial withdrawal does not terminate the policy, but the policy value is reduced accordingly.
  • Partial withdrawals may incur surrender charges and may affect the policy's death benefit.
  • The surrender value is generally equal to the policy account value less any applicable surrender charges.
  • The policy account value fluctuates with the market performance of the underlying funds, so the surrender value is also subject to market conditions.
  • Early surrender charges are usually higher and decrease as the policy term extends, to encourage long-term holding.
Types of Investment-linked Funds
  • A deposit fund primarily invests in bank deposits or money market instruments, with lower risk.
  • Returns are typically lower but relatively stable, suitable for investors with lower risk tolerance.
  • Deposit funds do not provide capital protection guarantees and still carry certain credit risk.
  • Fund switching allows the policyholder to move funds in the policy account from one linked fund to another.
  • Policyholders can adjust their fund allocation based on changes in market conditions or investment objectives.
  • Some policies offer a number of free switches per year; additional switches may incur a switching fee.
Risks of ILAS
  • The main investment risk of ILAS is market risk: the value of linked funds is subject to market fluctuations and may fall.
  • The policyholder bears all investment risk; the principal is not guaranteed and actual returns may be lower than expected or even result in losses.
  • Additionally, the fee structure of ILAS also impacts actual investment returns.
Comparison
  • ILAS returns depend on the market performance of linked funds, with no guarantees; they can go up or down.
  • Guaranteed policies (e.g., term life, whole life) provide definite policy cash values or death benefits unaffected by market fluctuations.
  • Both policy types provide life insurance protection, but their return mechanisms and risk profiles are entirely different.
Code of Sales Practice
  • The cooling-off period is an important consumer protection mechanism that allows policyholders time to reconsider after receiving policy documents.
  • During the cooling-off period, the policyholder can cancel the policy and receive a refund of premiums paid (which may be subject to market value adjustment).
  • According to the Hong Kong Insurance Authority's guidelines, the cooling-off period for ILAS is generally 21 days.
  • The Principal Brochure is an important document in the ILAS sales process that must be provided to prospective policyholders before the sale.
  • Its content includes the main features of the policy, fee structure, risk disclosure, and information on the linked funds.
  • The purpose is to ensure clients make an informed decision about taking out the policy.
Ethics and Conduct
  • Ethical conduct requires insurance intermediaries to deal with clients honestly and fairly, fully disclosing all relevant information.
  • Concealing fees, exaggerating returns, and applying pressure are all unethical behaviours that violate regulatory requirements.
  • Clients have the right to make their own informed decision about taking out the policy.
  • Under ethical conduct principles, insurance intermediaries are obligated to disclose the nature of any conflict of interest to clients, ensure clients understand the situation, and must place the client's best interests above their own.
  • Concealing a conflict of interest is a serious misconduct that may result in penalties including licence revocation.
Policy Illustration Documents
  • The policy illustration document shows the potential policy value under official assumed investment return rates (0%, 3%, 6%, 9% for Version 1; or 0%, 3%, 6% for Version 2 from 1 January 2015 onwards, per Study Notes Section 4.15.1).
  • The document is not a guarantee but assists clients in understanding the impact of fee deductions and return rates on the policy value.
  • Intermediaries must explain to clients the hypothetical nature of the illustration to avoid misunderstanding it as a guaranteed return.
  • The principal brochure is an important investor protection document that intermediaries must provide to clients before policy application.
  • The KFS is a standardised disclosure required by IA Guideline GL15, prepared by the insurer in plain language and given to the client before signing the application, so that the client can quickly grasp the ILAS's key information.
  • It applies to all ILAS products (single- or regular-premium) and works alongside the fund-level KFS for Investment Choices. The intermediary must walk the client through the KFS, fund KFS and policy provisions together.
Policy Administration and Policyholder Reporting
  • This helps policyholders monitor policy performance and understand the impact of charges.
  • They also record fund switches, premium allocations and other key transactions.
Features of Investment-linked Life Insurance Schemes
  • ILAS premiums are divided into two parts: one part is used to purchase life insurance coverage, known as the risk premium or cost of insurance; the other part is invested in selected investment funds.
  • The risk premium typically increases as the insured person ages, thereby reducing the amount available for investment.
Types of Fees
  • Common charges in investment-linked life insurance policies include: policy fee, insurance charge (risk premium), fund management fee, switching fee (charged when the policyholder changes their fund allocation) and early surrender charges.
  • Switching fees are charged when the policyholder switches their chosen funds; some policies provide a certain number of free switches per year.
Basic Calculations
  • The surrender value of an investment-linked life insurance policy depends on the number of fund units held by the policyholder and their current unit value, minus any surrender charges.
  • Since fund values fluctuate with the market, the surrender value may be higher or lower than the premiums paid, and investors bear the investment risk.
Death Benefits
  • The death benefit of an investment-linked life insurance policy is typically the higher of the policy account value (fund value) or the minimum sum assured.
  • The minimum sum assured ensures that beneficiaries still receive a certain level of protection even when fund performance is poor, reflecting the life insurance function of ILAS.
  • The death benefit is the higher of the two figures: HK$1,200,000 > HK$1,000,000.
  • The beneficiary therefore receives HK$1,200,000.
  • If the account value were to fall below the minimum sum assured, the guaranteed HK$1,000,000 would act as a floor.
  • The claims process for death benefits typically includes submitting a death certificate, claim form, and policy documents. Death benefits are usually payable directly to the designated beneficiary without going through probate, which is a major advantage of life insurance.
Types of Investment-linked Funds
  • A deposit fund is the lowest-risk fund type within investment-linked life insurance, primarily investing in bank deposits and short-term money market instruments, with capital preservation as the objective.
  • Due to its lower but stable returns, the deposit fund is suitable for investors with low risk tolerance or those who wish to temporarily park their funds.
  • A target-date (or life-cycle) fund follows a pre-defined 'glide path': it overweights equities in the years far from the target date (usually retirement) and gradually shifts to bonds and cash as the target date approaches, reducing volatility.
  • It does not guarantee principal, is not a single-bond product, and is not manually rebalanced — its hallmark is 'set and forget' automatic rebalancing.
Fund Switching
  • Fund switching refers to the policyholder transferring funds in their investment-linked life insurance policy account from the currently invested fund to one or more other funds, to adjust their investment portfolio.
  • Some policies offer a certain number of free switches per year; additional switches beyond the free allowance are subject to a switching fee.
  • ILAS policies commonly allow a set number of free switches each year, with a fee for additional switches.
  • Switches are executed at the NAV of the next applicable valuation day (forward pricing).
  • Fund switching does not terminate the policy and does not require case-by-case regulatory approval.
  • ILAS policies typically allow several free fund switches per year, commonly 4 to 12.
Risks of Investment-linked Life Insurance
  • The core risk of ILAS is that the investment risk is borne by the policyholder. Fund performance is not guaranteed, and the policy account value may fall due to market fluctuations, potentially falling below the total premiums paid and resulting in investment losses.
  • This differs from traditional guaranteed policies, which provide a fixed return or minimum guaranteed amount.
  • I is correct: ILAS is an investment product whose return depends on fund performance.
  • II is correct: ILAS account assets sit with the insurer, exposing policyholders to insurer counterparty risk.
  • III is correct: heavy early surrender charges are a key ILAS risk.
  • IV is incorrect: the Hong Kong Deposit Protection Scheme covers bank deposits only, not ILAS.
Comparison with Other Policies
  • The account value of an ILAS is directly linked to the market performance of chosen funds, allowing investors to clearly understand where their money is invested and how it performs, offering relatively high transparency.
  • With-profits policy returns are determined by the insurer; investors may not have clear visibility into the specific investment arrangements, offering relatively lower transparency but usually providing some guaranteed element.
Taxation
  • Hong Kong abolished estate duty in 2006, so death benefits from life insurance policies are generally not subject to estate duty. Additionally, Hong Kong has no capital gains tax, and life insurance death benefits are generally not included in the beneficiary's salaries tax assessable income.
  • This is one of the tax advantages of ILAS in Hong Kong, facilitating wealth transfer planning. However, investors should consult professional tax advisors as individual circumstances may vary.
Premium Allocation
  • The premium allocation rate is the percentage of premium actually invested in the underlying funds after distribution and administration costs are deducted.
  • First-year allocation rates are typically lower (e.g. 50%–80%) and rise closer to 100% in later policy years.
  • The unallocated portion funds commissions, issuance costs and underwriting expenses.
  • Some ILAS use a dual-unit system. Initial units are fund units purchased in the early years of the policy (e.g., first two years), typically subject to higher management charges (e.g., 6% per annum) and may be wholly or partially forfeited upon early surrender. Accumulation units are fund units purchased later, with lower charges (e.g., 1% per annum) and generally freely redeemable.
  • This design is essentially a hidden surrender charge mechanism, ensuring the insurer can recover initial distribution and administrative costs.
  • Single premium ILAS involves paying all premiums in a single lump sum (typically a larger amount) and is suitable for investors with a sum of idle funds. Compared to regular premium plans, single premium plans typically have a shorter surrender charge period and relatively lower surrender charges, but may lack features such as 'allocation bonuses' or 'loyalty bonuses' offered by regular plans.
Bid-Ask Spread
  • The bid-offer spread is the difference between the offer (subscription) price and the bid (redemption) price, implicitly incurred when units are bought and sold.
  • It is a real cost to the policyholder that directly reduces investment returns.
  • Not every ILAS imposes a bid-offer spread; the KFS and Principal Brochure should be consulted.
  • The bid-offer spread is the offer price minus the bid price.
  • Commonly around 5%, it is an implicit cost when investors enter or exit the fund.
  • It is not commission, a benefit basis, or an MPF deduction.
Subaccount Structure
  • ILAS account value = number of units held × unit NAV.
  • 1,000 × HK$12.50 = HK$12,500.
  • Actual withdrawable amount would be net of any bid-offer spread, surrender charge and other applicable fees.
  • If the ILAS policy account value falls to zero (possibly due to severe market decline, prolonged non-payment of premiums, or continuous charge deductions), the policy automatically lapses and all coverage (including life assurance) terminates. The policyholder no longer holds any policy entitlements.
  • Insurers typically issue warning notices when the policy account approaches the minimum level, reminding policyholders to take action (such as paying additional premiums or reducing withdrawals) to prevent policy lapse.
  • Under Hong Kong insurance regulations, ILAS subaccount assets must be held separately (segregated) from the insurer's general assets. This means that even if the insurer faces financial difficulties or is wound up, assets in the subaccount belong to the policyholders and cannot be used to repay the insurer's other debts.
Fee Structure of Investment-linked Long Term Insurance
  • A 60% first-year allocation rate means only 60% of premium is actually used to buy fund units.
  • HK$60,000 × 60% = HK$36,000.
  • The remaining HK$24,000 covers distribution costs, commissions and administration expenses.
  • The bid-offer spread is the difference between the offer price at which the policyholder buys units and the bid price at which units are redeemed, typically 3%–5%. It is a common implicit cost in ILAS.
  • It is not a one-off charge — it can apply to every transaction (including fund switching) and erodes investment returns over time.
  • The policy administration charge is levied by the insurer at policy level to cover policy issuance, reporting and compliance costs. The fund management fee is charged by the fund manager at fund level and is already deducted from the daily NAV — unit prices are therefore net of fees.
Management Fees
  • The Fund Management Fee (FMF) accrues daily and is already reflected in the published unit NAV.
  • Policyholders will not see a separate deduction line item but bear the cost indirectly through a lower NAV.
  • The KFS therefore discloses it as a recurring charge in annual percentage terms for comparability.
  • Fund management fees are usually expressed as an annualised percentage of fund NAV.
  • They accrue daily and are reflected in the sub-fund unit price; the client does not pay them in cash.
  • They are separate from policy admin fees or cooling-off charges.
Surrender Charges
  • Early surrender typically attracts a high surrender charge, and first-year allocation rates are low so not all premium is invested.
  • The surrender value also reflects market fluctuations and fees already deducted (COI, admin charges).
  • ILAS surrender proceeds in Hong Kong are generally not subject to salaries tax or capital gains tax.
  • The year-3 surrender charge rate is 50%.
  • Surrender charge = HK$200,000 x 50% = HK$100,000.
  • Net surrender value to the client = HK$200,000 - HK$100,000 = HK$100,000.
Partial Withdrawal
  • A partial withdrawal reduces the units held, directly lowering both account value and the base for future compounding.
  • If the death benefit is the higher of account value or minimum sum assured, the protection may also fall.
  • A withdrawal may attract a fee and must leave a minimum holding in the account.
  • Partial withdrawal redeems units and reduces the account value.
  • Because many ILAS death benefits depend on account value or premiums paid, the benefit may be reduced.
  • It generally does not need beneficiary consent but may be subject to minimum balance and withdrawal fees.
Suitability Assessment
  • ILAS is a long-term investment with heavy early-year surrender charges, which conflicts with a client's short-term liquidity need.
  • ILAS does not offer guaranteed returns; returns depend on the chosen funds' market performance.
  • Suitability assessment is mandatory and cannot be waived by a client's signed consent; recommending purely for commission breaches ethical standards.
  • The long term and high-risk fund mismatch the client's profile, so the sale is unsuitable.
  • The intermediary should rely on FNA/RPQ outcomes, not a disclaimer.
  • The IA pays special attention to sales to elderly clients.
Key Facts Statement (KFS)
  • I is correct: the KFS must set out product highlights in plain language.
  • II is correct: the KFS is a mandatory pre-sale disclosure document.
  • IV is correct: the premium allocation rate and surrender charge schedule are core KFS disclosures.
  • III is incorrect: the KFS is a summary and cannot replace the Principal Brochure that contains full terms.
  • The KFS is a concise 4-8 page document outlining features, fees, risks and terms.
  • It does not replace the policy contract or guarantee returns.
Cooling-Off Period
  • The ILAS cooling-off period is generally 21 calendar days after policy delivery or the issue of the cooling-off notice, whichever is earlier.
  • If cancelled within the period, the insurer refunds the premiums paid but may apply a market-value adjustment to reflect any fall in fund value.
  • The adjustment is downward only; policyholders do not share in market gains.
  • From 2 May to 18 May is 16 days, within the 21-day cooling-off period.
  • The insurer refunds premiums paid, subject to a market value adjustment (MVA).
  • Cooling-off applies to individual ILAS policies as well.
Disclosure Requirements
  • ILAS selling must balance disclosure of charges, risks and product limitations, not just returns.
  • Past performance is not indicative of future returns and this must be clearly highlighted.
  • Disclosure rules cover both verbal and written communications, and breaches can attract disciplinary action.
  • Guidelines such as GL26/GL15 and the ILAS Code require disclosure of fees, risks and cooling-off rights.
  • Intermediary commission and any rebate arrangements must also be disclosed for transparency.
  • Missing any item is inadequate disclosure.
Surrender Value Calculation
  • For a regular premium ILAS policy, a substantial part of the units assigned in the first year is redeemed to pay the 'long-term' charges arising from initial distribution and policy issuance costs.
  • As a result, the policyholder might not own any investment units for the first year of premium payments, so the surrender value on a first-year surrender can be very low or close to zero.
  • This illustrates that ILAS is a long-term investment product, and early surrender leaves the customer with far less than the premiums paid.
  • The surrender value of ILAS = Current policy account value (market value of fund units) - Surrender charges - Other applicable charges (such as administrative fees). Surrender charges are typically highest in the early years of the policy and decrease with the holding period.
  • If surrendered in the early years of the policy, surrender charges may be very high, and the policyholder may receive far less than the total premiums paid. This is a significant cost risk of ILAS; investors must fully understand the surrender charge structure before purchasing.
  • When evaluating early surrender of ILAS, comprehensive consideration should be given to: (1) Surrender charges — the immediate cost of early surrender; (2) Remaining investment term — whether sufficient time remains to achieve investment objectives; (3) Returns from alternatives — the opportunity cost of reinvesting surrender proceeds in other instruments; (4) Tax implications; (5) Protection needs — whether adequate coverage remains after surrender.
Code of Practice for ILAS
  • The Code requires FNA and RPQ to ensure product suitability.
  • Intermediaries must provide the KFS and IFS and fully disclose fees and risks.
Investment-linked Long Term Insurance Compliance
  • A post-sale call is made by an independent staff member to confirm the client's understanding.
  • It helps detect mis-selling early and allows cancellation within the cooling-off period.
  • It is not for upselling or chasing premiums.
Policy Loan
  • Traditional life insurance (such as whole life policies) typically has a guaranteed cash value, which policyholders can use as collateral for policy loans. However, the value of ILAS policies depends entirely on fund market performance and is more volatile; most insurers do not offer traditional policy loan facilities for ILAS.
  • Some ILAS policies may offer a similar partial withdrawal feature, but this directly reduces the policy's investment account value, unlike a traditional policy loan.
Leverage Effect
  • Some ILAS policies or their available funds allow the use of leverage (e.g., borrowed investment), which can amplify investment returns but equally amplifies losses. In adverse market conditions, leverage can cause the policy account value to drop sharply, potentially exceeding the invested principal.
  • Regulators impose restrictions on the use of leverage in ILAS to protect investors. Salespersons must fully disclose leverage risks to clients before the sale and ensure clients understand the implications.
  • When selling ILAS containing leveraged funds, salespersons are responsible for fully explaining to clients how leverage works (amplifying both gains and losses), the potential additional risks (including possible losses exceeding principal), and that leveraged funds are not suitable for conservative or low-risk-tolerance investors.
  • Under regulatory requirements, clients must make informed investment decisions after fully understanding the relevant risks. Salespersons must not only emphasise the potential high returns of leverage while neglecting risk disclosure.
Charges and Fees
  • The policy fee is a fixed administrative charge levied by the insurer, typically deducted as a fixed amount (e.g., HK$50/month) from the policy account monthly or quarterly, unrelated to the total policy account value. This fee covers administrative costs of managing the policy.
  • For investors with a smaller policy account, the fixed policy fee represents a proportionally higher percentage of total investment and has a greater impact. Therefore, ILAS is generally not suitable for investors with smaller investment amounts.
  • A premium holiday refers to a period when the policyholder temporarily stops paying premiums due to financial difficulties or other reasons, while the policy continues to remain in force. During the premium holiday, policy charges (such as protection charges and management fees) continue to be deducted from the policy account.
  • If the premium holiday is too long, the policy account value may be depleted by ongoing charges, causing the policy to lapse. Different insurers have different rules regarding premium holidays; these should be understood before purchasing.
Entry Age and Policy Term
  • ILAS is designed as a long-term investment tool and typically has a longer minimum holding period (commonly 10 to 25 years), with a declining surrender charge structure (decreasing year by year over the policy term) to encourage long-term holding. Early surrender before the minimum holding period typically incurs significant surrender charges.
  • Regulators require salespersons to fully explain the long-term commitment nature of ILAS before the sale, ensuring clients understand this is a long-term financial commitment unsuitable for those with short-term liquidity needs.
  • Age limits are not uniformly fixed by the IA but set by each insurer per product. Minimum ages can be as low as 15 days (children's ILAS) or 18; maximum ages typically range from 65 to 80, with some policies capping by 'attained age at maturity' rather than at issue.
  • Because ILAS is a long-term vehicle, the intermediary should specifically consider whether the client has sufficient time horizon to smooth out market volatility and absorb early-year surrender-charge risks.
Regulatory Framework for ILAS
  • The IA's ILAS regulatory framework (notably GL15, the Code of Conduct and the sales-process requirements) requires intermediaries to maintain complete sales records — FNA, RPQ, IFS and (in some firms) call recordings — to evidence the suitability assessment and key disclosures.
  • Records are retained for a number of years (typically at least 7) to provide an audit trail in complaints or regulatory investigations. Clients cannot unilaterally require destruction, and retention is also governed by the Personal Data (Privacy) Ordinance.

Part 5: Regulatory Framework in HK

Paper V — Investment-linked Long Term Insurance · Part 5: Regulatory Framework in HK

Regulators
  • The Insurance Authority (IA) is the statutory regulator of Hong Kong's insurance industry, responsible for regulating insurers and insurance intermediaries.
  • Its responsibilities include licensing, ongoing supervision, setting regulatory standards, and enforcement actions.
  • Regulating banking is the responsibility of the HKMA; regulating the securities market is the responsibility of the SFC.
  • ILAS is primarily regulated by the Insurance Authority (IA), but due to its investment component, the SFC also has regulatory oversight over ILAS-related intermediaries who sell through banks (licensed corporations).
  • When banks sell ILAS through financial advisors, the relevant personnel may need to hold both an IA insurance licence and an SFC Type 1 (dealing in securities) or other licence.
  • The regulatory overlap arises because ILAS has characteristics of both insurance and investment products.
Insurance Ordinances, Codes and Guidelines
  • The Insurance Ordinance is the primary legislation regulating the insurance industry in Hong Kong, covering the authorisation of insurers, capital requirements, and the licensed insurance intermediary system.
  • The purpose of the Ordinance is to protect the interests of policyholders and maintain the sound development of the insurance industry.
  • The Insurance Authority (IA) is the primary body that enforces the Insurance Ordinance.
  • IA issues the Code of Conduct setting out core requirements.
  • Other ordinances are administered by different regulators.
Anti-Money Laundering
  • AMLO requires insurance intermediaries to conduct Customer Due Diligence (CDD), including identifying and verifying the client's identity and beneficial ownership.
  • They must continuously monitor client relationships and transactions, and file Suspicious Transaction Reports (STRs) with the Joint Financial Intelligence Unit (JFIU) of the Hong Kong Police Force when suspicious activity is identified.
  • Complete client information and transaction records must be kept for inspection by regulatory authorities.
  • CDD core includes identifying customer and beneficial owner.
Personal Data Protection
  • The Personal Data (Privacy) Ordinance sets out six data protection principles, including: data may only be used for the purposes stated at collection, data accuracy must be ensured, there must be reasonable retention periods, and security measures must be implemented.
  • Insurance intermediaries must not use personal data for other purposes or transfer it to third parties without the client's consent.
  • Violations of the Ordinance may result in civil or criminal liability.
  • DPP1 and DPP3 require purpose notification at collection and use limited to those purposes.
  • Direct marketing requires explicit client consent.
  • PDPO (Cap. 486) requires personal data to be used only for the purposes stated at collection; transferring data to a third party for direct marketing falls under Part VIA, which requires prior explicit consent (opt-in) and an opt-out mechanism.
Insurance Regulations, Codes and Guidelines
  • Under Hong Kong's Insurance Ordinance, any person who carries on insurance business in Hong Kong without authorisation from the Insurance Authority commits an offence and may be prosecuted and face criminal liability.
  • The Insurance Ordinance aims to protect the public interest by ensuring that companies and individuals providing insurance services in Hong Kong meet relevant requirements and possess the necessary qualifications.
  • The Code of Conduct for Licensed Insurance Agents sets out the standards of conduct that insurance agents must observe in their practice. Core requirements include: acting honestly and fairly, exercising due care and diligence towards clients, identifying and assessing client needs, and placing client interests first.
  • The Code also sets requirements on qualifications maintenance, continuing training and record-keeping for licensed agents.
  • GL23 is a guideline issued by the Insurance Authority that sets the 'fit and proper' criteria that insurance intermediaries (insurance agents and brokers) must meet, covering aspects such as character and integrity, professional qualifications and knowledge, financial soundness and reputation.
  • The Insurance Authority refers to the criteria set out in GL23 when approving and regulating licensed insurance intermediaries to ensure the quality of industry practitioners.
Securities Regulations and Code of Conduct
  • Under Hong Kong's Securities and Futures Ordinance, market misconduct encompasses various forms including: insider dealing (trading using non-public inside information), false trading, market manipulation, and disclosing false or misleading information about the market.
  • Market misconduct not only harms individual investors but also undermines the fairness and integrity of the market, threatening the healthy development of the entire financial market.
Other Relevant Regulations
  • AMLO requires insurance intermediaries to conduct customer due diligence (CDD) before establishing a business relationship or conducting a transaction, including identifying and verifying the client's true identity and understanding the purpose and nature of the business relationship.
  • If an intermediary suspects a transaction involves money laundering or terrorist financing, they must submit a suspicious transaction report (STR) to the Joint Financial Intelligence Unit (JFIU).
  • Under the PDPO, organisations collecting personal data (including insurers) must: inform the data subject of the purpose and use of data collection, only use the data within the stated purpose, take reasonable measures to protect data security, and allow data subjects to access and correct their personal data.
  • Violations of the PDPO may result in civil and criminal liability, including fines and imprisonment.
  • Collecting HKID for verification and securely destroying expired documents are PDPO-compliant.
  • Undisclosed marketing and publishing client lists breach DPP3.
Policyholders' Protection Scheme
  • PHS coverage for non-investment-linked long term insurance: up to 90% of the policy benefit payable or HK$500,000 per policyholder, whichever is LOWER.
  • For example: if the policy benefit is HK$800,000, the protection is min(90% × HK$800,000, HK$500,000) = min(HK$720,000, HK$500,000) = HK$500,000.
  • Key point: it is the LOWER of the two amounts, not the higher.
  • PPS protects policyholders if the insurer becomes insolvent.
  • Unrelated to investment returns or cooling-off.
  • The ICB is Hong Kong's independent insurance complaint body, providing free monetary dispute adjudication for individual policyholders subject to a per-case claim cap; rulings are binding on member insurers but voluntary for complainants.
Key Facts Statement (KFS)
  • The KFS is a mandatory pre-sale disclosure document designed to present in plain language, before purchase: (1) key product features; (2) key risks (including investment risks); (3) charges and fees; (4) cooling-off period arrangements.
  • The KFS cannot replace the Policy Illustration; both serve distinct regulatory purposes.
  • Both are required documents serving different functions — the KFS provides a concise summary, while the Policy Illustration provides detailed actuarial projections.
  • KFS must be provided and explained before application.
  • It is a critical pre-sale disclosure requirement.
  • The KFS summarises key risks and fees, while the illustration document shows projected policy values under different investment return assumptions.
Fee Structure of Investment-linked Long Term Insurance
  • The COI in ILAS is the charge for maintaining life insurance protection, deducted from the policy account. Its characteristics: (1) typically deducted monthly; (2) calculated based on the insured's age (higher with age) and sum assured; (3) increases continuously with age.
  • This is one of the key differences between ILAS and pure investment products, potentially eroding investment returns over the long term.
Securities and Futures Ordinance Compliance
  • Under the SFO, before ceasing regulated activities, intermediary institutions must: (1) give advance notice to the SFC; (2) arrange to transfer or properly deal with client accounts, assets and outstanding transactions; (3) ensure client assets are safely transferred.
  • Immediate cessation without properly handling client affairs is not permitted, to protect client interests.
  • SFO s.103 prohibits issuing investment invitations to the public without authorised documents.
  • SFC-authorised offering documents must be used.
Market Misconduct
  • SFO Parts XIII and XIVA defines six categories of market misconduct: (1) Insider Dealing; (2) False Trading; (3) Price Rigging; (4) Disclosure of Information about Prohibited Transactions; (5) Disclosure of False or Misleading Information Inducing Transactions; (6) Stock Market/Futures Market Manipulation.
  • The MMT can impose various sanctions including disqualification orders, fines and prohibition orders.
  • Insider dealing is market misconduct.
Investment-linked Long Term Insurance Compliance
  • The core of the Risk-Based Approach: identify and assess ML/TF risks of different clients, products and geographies, then focus compliance resources on higher-risk areas.
  • High-risk clients (e.g., Politically Exposed Persons, high net worth clients with complex structures) require Enhanced Due Diligence (EDD); lower-risk clients may receive Simplified Due Diligence (SDD).
  • This ensures efficient allocation of compliance resources proportionate to risk.
  • The cooling-off period does not exempt AML/CFT obligations.
Insurance Authority (IA)
  • IA regulates insurers and licensed insurance intermediaries' conduct.
  • Linked funds are SFC-authorised and fall under SFC's purview.
  • IA assesses fit-and-proper status for insurance intermediaries.
  • Other authorities do not licence insurance intermediaries.
  • The Insurance Authority (IA) is Hong Kong's independent insurance regulator, with main functions including: (1) Supervising the solvency and financial soundness of insurers; (2) Licensing insurance intermediaries (insurance agents and brokers) and managing their licensing matters; (3) Ensuring insurance intermediaries comply with codes of conduct; (4) Setting relevant rules and conduct requirements for ILAS sales.
  • Authorisation of funds available within ILAS is the responsibility of the SFC, not the IA.
Regulatory Framework for ILAS
  • SFC authorises linked funds and reviews their offering documents.
  • Policy wording and intermediary licensing fall under IA.
Cooling-Off Period
  • Under IA guidelines the ILAS cooling-off period is 21 calendar days.
  • It runs from delivery of the policy or the cooling-off notice, whichever is earlier.
Suitability Assessment
  • FNA and RPQ assess client risk tolerance.
  • Recommending a mismatched product breaches suitability.
  • Mismatch transactions must be documented and escalated per firm procedure.
  • Altering RPQ or using a relative's name is dishonest.
  • When a client's request does not match their risk assessment results, the salesperson must clearly explain the reasons for unsuitability. If the client still insists after fully understanding the risks, the salesperson should: (1) Make detailed written records noting that risks have been explained to the client; (2) Have the client sign a relevant declaration confirming the decision is made knowingly; (3) Consider whether to proceed with the transaction (different situations may require different handling).
  • Amending assessment results to match client requests is serious misconduct that may constitute a violation and lead to licence revocation.
Sales Process Requirements
  • Post-sale call is a key control to verify client understanding.
  • Covers product nature, charges and cooling-off rights.
  • GL30 requires audio recording for elderly client sales.
  • To safeguard vulnerable customer interests.
  • Under Hong Kong regulatory requirements, insurance intermediaries selling ILAS must proactively disclose commission information to clients before the sale, including the approximate amount or percentage range of commissions relative to premiums. This requirement aims to ensure clients are aware of potential conflicts of interest on the part of the intermediary, enabling better assessment of the objectivity of their recommendations.
  • Commission disclosure is an important measure to enhance sales transparency and protect investors. Salespersons must not in any way mislead clients about their remuneration arrangements.
Disclosure Requirements
  • GL26 requires IFS to disclose intermediary remuneration rate.
  • Increasing transparency in the sales process.
  • Intermediaries must disclose identity, principal and product nature.
  • Personal portfolios and internal data are not required.
  • Under GL15 and GL26, intermediaries must disclose commission arrangements (I), the surrender charge schedule (II) and the cooling-off right (III).
  • Highest single-day fund returns (IV) are not a prescribed disclosure item and may mislead clients; intermediaries should show reasonable scenarios in the illustration document instead of extreme single-day performance.
Anti-Money Laundering (AML) Requirements
  • AMLO Cap. 615 prohibits tipping-off the client.
  • Report internally to compliance who files an STR with JFIU.
  • Under Hong Kong's AML regulations, insurance intermediaries must fulfil the following AML/CFT obligations when selling ILAS: (1) Know Your Customer (KYC) — verifying the client's identity and background; (2) Understanding the source of the client's funds; (3) Ongoing customer due diligence; (4) Identifying and reporting suspicious transactions by submitting Suspicious Transaction Reports (STRs) to the Joint Financial Intelligence Unit (JFIU).
  • Failure to comply with AML requirements may result in serious legal consequences, including criminal prosecution and licence revocation.
  • AMLO Cap. 615 requires intermediaries to perform CDD: identify and verify the client, identify beneficial owners, understand the purpose and nature of the relationship, ascertain source of funds and conduct ongoing monitoring.
  • Enhanced due diligence (EDD) is required for higher-risk customers (e.g. PEPs); suspicious transactions must be reported to the Joint Financial Intelligence Unit (JFIU) via a Suspicious Transaction Report (STR).
Code of Practice for ILAS
  • GL15 requires FNA and RPQ to assess suitability.
  • Advancing premiums and promising fixed returns are violations.
  • Post-sale call and disclosing cooling-off are required.
  • Hiding charges or deciding for the client are violations.
  • Under Hong Kong's Code of Practice for ILAS, before selling ILAS, insurance intermediaries must conduct: (1) Needs Analysis — understanding the client's financial situation, financial objectives, existing coverage and investments, family circumstances, etc.; (2) Risk tolerance assessment — understanding the client's investment risk preference and ability to absorb losses.
  • Based on this, intermediaries must ensure the recommended ILAS product is suitable for the client. If unsuitable, the product must not be recommended; if the client insists, careful handling and written records are required.
Policy Illustration Documents
  • The illustration shows projected account values under different assumed return rates.
  • Returns are not guaranteed; past performance is not indicative.
Client Agreement
  • A Client Agreement clarifies scope and obligations.
  • KFS cannot be substituted.
  • The Client Agreement is a written agreement between the insurance intermediary (agent or broker) and the client, with main content including: the intermediary's licensing information and capacity (whether the agent represents the insurer or is an independent broker), rights and obligations of both parties, and fee arrangements (such as how commissions or fees are collected).
  • The purpose of the Client Agreement is to ensure clients clearly understand the intermediary's identity and responsibilities, as well as service arrangements, promoting transparency and protecting consumer rights.
  • The client documentation must clearly state the intermediary's identity and licensing information (I), the nature and scope of services (II) and the complaint channels (III) including ICB contact details.
  • Intermediaries must not give personal guarantees of future investment returns (IV); ILAS unit values depend on the underlying fund performance, and such guarantees are misleading and breach the Code of Conduct and GL15.
Calculations
  • Step 1 (95% allocation rate): HK$100,000 × 95% = HK$95,000 allocated.
  • Step 2 (5% front-end charge on the allocated amount): HK$95,000 × (1 − 5%) = HK$90,250 actually invested into the subaccount.
  • Note: this item treats the allocation rate and the front-end charge as two separate deductions to test both concepts.
Ethics and Conduct
  • Forgery breaches honesty and fair-treatment principles.
  • A serious violation of the Code of Conduct.
Product Key Facts Statement (KFS)

Insurance intermediaries must provide clients with the KFS before selling ILAS and give clients sufficient time to read and understand it. The KFS is not the policy contract and does not replace the full policy terms.

SFC-authorised Funds
  • Under Hong Kong regulations, investment funds available for selection in ILAS policies must be authorised by the Securities and Futures Commission (SFC) before they can be offered to the Hong Kong public. The SFC reviews funds' investment policies, fund management companies, fee structures, etc.
  • The IA regulates ILAS policies themselves and insurance intermediaries; the MPFA oversees MPF schemes; HKEX manages exchange operations. The four authorities each have clearly defined roles.

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