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MPF intermediaries
MPFMPF Intermediaries ExaminationIIQE MPF · Topic 7
MPF exam chapter 7 (20% of the paper, the second heaviest): what counts as a regulated activity, registration of principal and subsidiary intermediaries, the frontline regulators, the statutory conduct requirements, continuing training, discipline, appeals and the related offences.
8 min read6 sections
Checked against the MPF Study Notes, Tenth Edition (June 2026; for exams from 1 Oct 2026), chapter 7, and the MPFA pages on registration requirements (last reviewed 15 Jun 2026), continuing training (23 Jun 2026) and the regulatory regime for MPF intermediaries. Reviewed 6 Nov 2026.. Independent prep, not endorsed by the MPFA or any examination provider.
Chapter 7 is 20% of the paper, about 16 questions. Registration conditions and the conduct requirements produce most of them.
Since 1 November 2012 the MPFSO has prohibited anyone from carrying on a regulated activity in the course of business or employment, or for reward, unless registered (or another exception applies). It is also an offence to hold yourself out as doing so, or to use the titles principal intermediary or subsidiary intermediary without registration.
| Principal intermediary (PI) | Subsidiary intermediary (SI) | |
|---|---|---|
| Who | A business entity | An individual acting for a PI |
| Qualification | Type A regulatee: an authorised long term insurer or licensed long term insurance broker company (IA); an authorized financial institution registered for SFO Type 1 or 4 (MA); a corporation licensed for SFO Type 1 or 4 (SFC) | Type B regulatee of an industry regulator, and not a Type A regulatee |
| Examination | Not applicable | Passed a qualifying examination within 1 year before applying (the VTC's MPF Schemes Examination or the HKSI Institute's MPF Intermediaries Examination) |
| Accompanying application | Approval of at least one responsible officer, and of that officer's attachment | Approval of attachment to a PI, applied for by the PI |
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A principal intermediary is a business registered by the MPFA that is a Type A regulatee of the IA, SFC or Monetary Authority and has at least one responsible officer. A subsidiary intermediary is an individual Type B regulatee attached to a principal intermediary.
A new subsidiary intermediary applicant must have passed the examination within 1 year before applying. Someone not registered as a subsidiary intermediary in the 3 years before applying must re-sit (MPFA, last reviewed 15 Jun 2026).
From 1 January 2024, subsidiary intermediaries need 15 hours each calendar year, including 4 hours of MPFA-approved core activities, prorated in the first year. Hours cannot be carried forward (MPFA, last reviewed 23 Jun 2026).
| Good standing | No Type A qualification revoked on disciplinary grounds in the past year, none suspended, no MPF registration revoked by the MPFA in the past year, not disqualified | Same tests applied to the Type B qualification |
The 1-year examination rule has an exception: an applicant whose SI registration was revoked within the previous 3 years need not re-sit, unless the revocation was for failing the continuing training requirement. An SI who has not been registered at all within 3 years before applying must re-sit and pass.
The MPFA keeps a public Register of Intermediaries, which also records disciplinary orders made in the last five years.
Trap: a PI is a firm and a Type A regulatee; an SI is an individual Type B regulatee. Options that swap A and B, or let an SI act without attachment to a PI, are wrong.
Takeaway: PI = Type A firm with a responsible officer. SI = Type B individual, attached to a PI, exam passed within 1 year.
A material decision is any decision about joining or participating in a particular MPF scheme, paying contributions (including voluntary ones) or investing in a particular constituent fund, the amounts involved, transferring benefits between schemes or funds or from an ORSO scheme into MPF, and claiming benefits. Inviting or inducing someone to make one, or giving an opinion on one (regulated advice), is a regulated activity.
When carrying on a regulated activity, a PI and its attached SIs must:
A PI must also keep records that let its frontline regulator check compliance, set up controls and procedures for its SIs, use best endeavours to make them follow those controls, and give its responsible officer enough authority and resources. The responsible officer must use best endeavours to carry out the specified responsibilities.
The MPFA's Guidelines on Conduct Requirements for Registered Intermediaries explain how to meet these duties. Frontline regulators apply them when supervising and investigating.
Trap: issuing an advertisement or document authorised by the SFC under section 105 of the Securities and Futures Ordinance is not by itself a regulated activity.
Takeaway: regulated activity = inducing a material decision or advising on one. Eight conduct duties, led by honesty, care, competence, suitability, disclosure and conflicts.