Functions of Appointed Service Providers 獲委任的服務提供者的職能

The Trustee’s Responsibility and Appointment Arrangements 受託人的統籌責任與委任安排

The trustee is the central party responsible for managing an MPF scheme. Assigning work to another service provider does not remove that overall responsibility: performing a particular task and being responsible for scheme management are distinct matters.

Subject to exceptions, the trustee must appoint an investment manager. Custody may be delegated to a custodian, while a trustee meeting the specified criteria may itself act as custodian. The trustee and custodian therefore need not always be separate institutions. [MPFA Study Notes, 10th edition, 3.2](https://www.mpfa.org.hk/en/-/media/files/supervision/mpf-intermediaries/registration-requirements/study_notes_10th_v1_eng.pdf#page=26)

Investment Manager Qualifications and Continuing Duties 投資經理的資格與持續責任

The investment manager manages scheme investments under its investment contract. Its corporate status matters: it must be incorporated in Hong Kong or be a re-domiciled company as defined in the Companies Ordinance (Cap. 622).

It also needs SFC licensing or registration for the business of Type 9 (asset management) regulated activity under Part V of the Securities and Futures Ordinance (Cap. 571). Authorisation for another type of regulated activity alone does not satisfy this requirement.

Appointment brings continuing obligations to observe the investment contract, applicable MPFA Guidelines and regulatory restrictions. Financial and other requirements must remain satisfied throughout the appointment; meeting them initially is insufficient. [MPFA Study Notes, 10th edition, 3.2(a)](https://www.mpfa.org.hk/en/-/media/files/supervision/mpf-intermediaries/registration-requirements/study_notes_10th_v1_eng.pdf#page=27)

Custodian Functions and Financial Requirements 保管人的職能與財務要求

Custody concerns the actual holding and safekeeping of trust assets. Common custodians include authorised institutions, such as banks, under the Banking Ordinance (Cap. 155), and trust companies registered under Part VIII of the Trustee Ordinance (Cap. 29).

For a registered trust company acting as custodian, the ordinary financial threshold is at least HK$150 million in each of paid-up share capital and net assets. Both measures must pass separately; adding them together does not satisfy the test.

A registered trust company may meet the financial requirements with at least HK$50 million in each measure if it also meets the other requirements under the Mandatory Provident Fund Schemes Ordinance. This lower threshold is conditional. The arrangement is addressed in section 68 of the Mandatory Provident Fund Schemes (General) Regulation (Cap. 485A). [MPFA Study Notes, 10th edition, 3.2(b)](https://www.mpfa.org.hk/en/-/media/files/supervision/mpf-intermediaries/registration-requirements/study_notes_10th_v1_eng.pdf#page=27)

An appointed custodian must take proper care of all scheme assets. Its contract is called the custodial agreement; contractual compliance sits alongside compliance with applicable MPFA Guidelines, regulatory restrictions, and continuing financial and other requirements.

The Marketing Role of MPF Intermediaries 強積金中介人的推銷角色

MPF intermediaries market MPF schemes. Identify the role by the work performed: scheme marketing belongs to the intermediary role, investment management to the investment manager, and asset custody to the custodian. Intermediary status alone does not establish eligibility to perform either of the other roles. [MPFA Study Notes, 10th edition, 3.2](https://www.mpfa.org.hk/en/-/media/files/supervision/mpf-intermediaries/registration-requirements/study_notes_10th_v1_eng.pdf#page=26)