PrepLicense: HK MPF · Study Notes · Chapter 7

MPF Chapter 7: MPF Intermediaries

This chapter focuses on practical conduct: registration categories, dual regulation, the roles of Principal Intermediaries (PI) and Subsidiary Intermediaries (SI), sales conduct requirements, and Continuing Professional Training (CPT).

1. Two Categories of MPF Intermediary

Principal Intermediary (PI): a corporate entity responsible for supervising its representatives. Subsidiary Intermediary (SI): a natural person who must be attached to one PI.

2. Dual Regulation Principle

Beyond MPFA regulation, intermediaries are supervised by their frontline regulator: securities-sector by the SFC, insurance-sector by the IA, banking-sector by the HKMA. A single breach may attract sanctions from both.

3. Registration Conditions

A PI must hold an SFC, IA or HKMA licence/registration. An SI must be attached to a PI, pass the VTC-administered MPF Intermediaries Examination, and meet 'fit and proper' requirements.

4. Suitability Principle

Before recommending an MPF scheme or fund, the intermediary must understand the client's financial position, investment objectives, age and risk tolerance, and make a reasonable recommendation supported by written records.

5. Client Disclosure

Intermediaries must clearly disclose their identity, registration number, attached PI, the range of schemes they may offer, and any commission or benefit they may receive.

6. Prohibited Conduct

No misrepresentation, omission of material facts, undue pressure, unauthorised instructions, or acceptance of secret profit.

7. Complaint Handling

Intermediaries and PIs must operate an internal complaint-handling mechanism. MPFA, SFC, IA and HKMA each maintain independent complaint channels.

8. Continuing Professional Training (CPT)

Intermediaries must complete minimum CPT hours per calendar year (typically 10 hours including MPFA-specified core topics; verify current requirements with MPFA). Failure may result in suspension or revocation of registration.

9. Conflict of Interest and Disclosure

Where the intermediary or any affiliate has any monetary or material interest in a transaction, it must be disclosed to the client in advance — including fund commissions, promotional fees and inter-institutional referral fees.

10. Advertising and Promotional Material

Promotional materials must be pre-approved internally by the PI and meet standards of fairness, clarity and non-misleading character. Past performance must carry a warning and may not guarantee future returns.

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本應用為獨立學習工具，與強制性公積金計劃管理局（MPFA）及職業訓練局（VTC）無關，亦未獲其認可。