Registration of MPF Schemes and Approval of Constituent Funds and Pooled Investment Funds 強積金計劃的註冊及成分基金與匯集投資基金的核准

Distinguishing Schemes, Funds and Regulatory Procedures 分清計劃、基金及監管程序

Constituent funds are the fund choices within an MPF scheme through which members invest contributions and accrued benefits. Pooled investment funds can serve as underlying investments of constituent funds. Schemes, constituent funds and pooled investment funds therefore represent different levels of regulatory oversight. [MPFA: explanation of schemes and funds](https://www.mpfa.org.hk/en/-/media/files/information-centre/publications/mpfa-annual-reports/eng/2024-25/mpfa-ar2024-25_eng.pdf)

The MPFA registers MPF schemes and approves constituent funds and pooled investment funds under the Mandatory Provident Fund Schemes Ordinance and its related rules and regulations. The SFC authorises master trust schemes and industry schemes, including their constituent funds, and pooled investment funds. Distinguish MPFA registration or approval from SFC authorisation: obtaining one does not replace the other’s applicable requirements. [Code on MPF Investment Funds](https://www.mpfa.org.hk/en/-/media/files/information-centre/legislation-and-regulations/codes/code_on_mpf_investment_funds.pdf)

Purpose of the MPFA’s Code 積金局守則的作用

The MPFA oversees the overall administration of the MPF System. Its [Code on MPF Investment Funds](https://www.mpfa.org.hk/en/-/media/files/information-centre/legislation-and-regulations/codes/code_on_mpf_investment_funds.pdf) mainly addresses operational and investment requirements. It adds requirements to those in MPF legislation, so products must satisfy both the applicable legislation and the Code.

The Code also explains how the MPFA and SFC divide their work on product approval and authorisation. The Code on MPF Investment Funds and the SFC Code on MPF Products address different aspects and must be read together; applicants cannot choose to comply with just one.

SFC Authorisation, Disclosure and Advertising Requirements 證監會的認可、披露及廣告規定

The SFC authorises the relevant MPF products and vets or authorises information disclosed in offering documents, advertisements and marketing materials. The [SFC Code on MPF Products](https://www.sfc.hk/-/media/EN/assets/components/codes/files-current/web/codes/sfc-code-on-mpf-products/sfc-code-on-mpf-products.pdf) sets product authorisation conditions and disclosure requirements for offering documents.

The SFC also licenses investment managers, and the SFC Code on MPF Products specifies the qualifications and experience required of managers of the relevant products. Product authorisation and the investment manager’s compliance are separate regulatory matters.

Advertisements, invitations and other documents issued to the public in Hong Kong inviting participation or investment in master trust schemes, industry schemes or pooled investment funds must comply with the SFC’s Advertising Guidelines. Registration, approval or authorisation of the product does not remove the compliance requirements for its promotional materials.

Document Changes after Authorisation 獲認可後的文件更改

Offering documents disclose product information to prospective members or investors. Constitutive documents establish the basic arrangements for forming and operating a scheme or fund, such as a trust deed. Changes to constitutive documents or product arrangements may also require revisions to offering documents, so distinguish the two types of document. [Code on MPF Investment Funds](https://www.mpfa.org.hk/en/-/media/files/information-centre/legislation-and-regulations/codes/code_on_mpf_investment_funds.pdf)

Authorised products remain subject to ongoing requirements. Certain revisions to offering documents require the SFC’s prior approval, including revisions arising from changes to constitutive documents, key operators or investment objectives; these examples are not exhaustive. The examination point is whether prior approval is required. Where it is, notification afterwards cannot replace it. [SFC Code on MPF Products](https://www.sfc.hk/-/media/EN/assets/components/codes/files-current/web/codes/sfc-code-on-mpf-products/sfc-code-on-mpf-products.pdf)