“Straight Pass-on” of Cost Savings and “Corresponding Fee Reduction” 「直接轉移」減省成本和「相應減費」的規定

Statutory Purpose and the Two Requirements 法定目的與兩項要求

When eMPF reduces scheme administration costs, members should receive the benefit through lower fees. The Mandatory Provident Fund Schemes Ordinance establishes two linked requirements: “straight pass-on” controls the administration fee, while “corresponding fee reduction” checks the effect on the constituent fund’s overall expenses. [MPFA Study Notes, tenth edition, section 8.3](https://www.mpfa.org.hk/en/-/media/files/supervision/mpf-intermediaries/registration-requirements/study_notes_10th_v1_eng.pdf)

Straight Pass-on: the Administration Fee Ceiling 「直接轉移」：行政費的上限

Compare the administration fee charged by the trustee with the eMPF Platform fee that the trustee pays to the eMPF Company. The administration fee may equal or fall below that platform fee, but the trustee cannot add an administration margin above it.

This comparison concerns the administration component. It does not make the platform fee a ceiling for every charge or for the constituent fund’s overall fund expense ratio.

Corresponding Fee Reduction: Checking Overall Expenses 「相應減費」：檢查整體開支

The fund expense ratio expresses a fund’s expenses as a percentage of its size. Corresponding fee reduction requires the constituent fund’s overall fund expense ratio to capture the entire saving from eMPF, producing a matching reduction in overall fees.

A lower administration fee alone is therefore insufficient. For example, increasing another charge to cancel out the administration fee reduction would fail the requirement if the overall fund expense ratio did not reflect the required saving. [MPFA Study Notes, tenth edition, sections 5.10 and 8.3](https://www.mpfa.org.hk/en/-/media/files/supervision/mpf-intermediaries/registration-requirements/study_notes_10th_v1_eng.pdf)

An Insufficient Reduction: Repayment into the Fund 減幅不足：由受託人把差額付回基金

If a constituent fund’s fund expense ratio does not capture the full required reduction, the trustee must pay the difference back into that constituent fund. The trigger is an insufficient reduction, the payer is the trustee, and the recipient is the affected fund.

Distinguish repayment into the fund from a cash payment to an individual member. The requirement restores the difference to the fund; refunding an employer’s contributions or paying the eMPF Company would not fulfil it. [MPFA Study Notes, tenth edition, section 8.3](https://www.mpfa.org.hk/en/-/media/files/supervision/mpf-intermediaries/registration-requirements/study_notes_10th_v1_eng.pdf)