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MPF intermediaries
MPFMPF Intermediaries ExaminationIIQE Paper 1 · Topic 6
IIQE Paper 1 chapter 6 (21% of the paper, the second heaviest): the Insurance Ordinance (Cap. 41) and the Insurance Authority, authorisation and supervision of insurers, the Code of Conduct for Insurers, the Insurance Complaints Bureau, and the licensing regime for insurance intermediaries in force since 23 Sep 2019, with its conduct requirements, discipline and CPD rules.
10 min read6 sections
Checked against the IA Paper 1 (Principles and Practice of Insurance) Study Notes, 2024 Edition (8th edition, Nov 2024; for exams from 17 Feb 2025), chapter 6; Insurance Ordinance (Cap. 41) ss.68, 81 and 90; Cap. 41L; IA Guidelines GL10, GL12, GL18, GL22, GL23 and GL24; Code of Conduct for Licensed Insurance Agents and Code of Conduct for Licensed Insurance Brokers; Insurance Complaints Bureau Terms of Reference and FAQs (icb.org.hk, read 6 Nov 2026). Reviewed 6 Nov 2026.. Independent prep, not endorsed by the Insurance Authority or the VTC.
Every note. Every question. One pass.
4 more sections of this note are part of Premium.
Passes from HK$148, pay once, no auto-renew
HK$1,500,000 under the ICB's current Terms of Reference (icb.org.hk, read 6 Nov 2026). The IA Paper 1 Study Notes, 2024 Edition, still give the older HK$1,000,000. The complaint must be about a personal policy and be lodged within 6 months of the insurer's final decision; the service is free.
It binds the member insurer, which has no right of appeal. The complainant is not bound and can still take the matter to court.
At most 4 insurers, of which at most 2 may be long term insurers.
Under section 81 of the Insurance Ordinance, up to HK$10 million or three times the profit gained or loss avoided, whichever is greater.
Under the IA's GL24, at least 15 CPD hours in each assessment period from 1 August to 31 July, including at least 3 hours on ethics or regulations, reported by 30 September. Extra hours cannot be carried forward. A technical representative (agent) licensed only for restricted scope travel business needs 3 hours.
The IA's powers of intervention give supervision its teeth: limiting premium income, restricting new business or investments, requiring assets to be held by a trustee, ordering a special actuarial investigation, appointing a manager, and, the most serious, petitioning the court to wind the insurer up. Sanctions on insurers include revocation or suspension of authorisation, prohibition, reprimand and a pecuniary penalty (GL18).
Capital rules. The 2024 study notes still describe the older paid-up capital and solvency margin model. Since 1 Jul 2024 the risk-based capital rules apply instead. For the exam, know the purpose (keeping insurers able to pay claims), not the figures.
Trap: the IA regulates; it does not decide individual claims disputes. Those go to the ICB.
Takeaway: insurers are authorised, intermediaries licensed, both by the IA. IA over insurers from 26 Jun 2017; over intermediaries from 23 Sep 2019.
Since 23 Sep 2019, nobody may carry on a regulated activity in the course of business without an IA licence, whether or not he is an insurer's employee. The four regulated activities:
Exemptions include underwriting and claims processing for the insurer, loss adjusting, clerical work and the media. Staff who advise or sell are not exempt.
| Licence | Who | Acts for |
|---|---|---|
| Licensed individual insurance agent | An individual appointed directly by an insurer | The insurer |
| Licensed insurance agency | A business appointed by an insurer | The insurer |
| Licensed technical representative (agent) | An individual working for an agency | The agency |
| Licensed insurance broker company | A company acting for clients | The policy holder or proposer |
| Licensed technical representative (broker) | An individual working for a broker company | The broker company |
Every licensed agency and broker company must have at least one responsible officer (RO) approved by the IA, who supervises its regulated activities and its compliance with the conduct requirements.
Appointment limits. A licensed insurance agent (individual or agency) may be appointed by no more than 4 insurers, and no more than 2 of them may be long term insurers.
Section 68. An appointing insurer is liable for what its appointed agent does in regulated activities, so the client does not have to argue about whose agent he was. Where an agent acts for several insurers, they can be jointly and severally liable, subject to a defence where the agent's lack of authority was clearly disclosed in advance.
Multiple capacities. The agent/broker divide is kept: a person cannot act as both an agent and a broker, and a TR (agent) may serve only one agency.
Trap: "advising on a claim" or "persuading a client to surrender" is a regulated activity. Options treating after-sale work as unregulated are wrong.
Takeaway: four regulated activities, five licence types, max 4 insurers (2 long term) per agent. Section 68 makes insurers answer for their agents.