When an Intermediary Hard-Sells You an MPF Fund: Three Ways to Protect Yourself

This article is a rewrite of a report from November 2012.

On 1 November 2012 — the same day the Employee Choice Arrangement launched — the statutory regime regulating MPF intermediaries also took effect. Before recommending a fund, an intermediary must conduct a “suitability assessment”; if you suspect misconduct, the MPFA offers multiple complaint channels. Rules laid down in 2012 remain a shield against hard selling today.

What must an intermediary do before recommending a fund?

Conduct a “suitability assessment” to understand your risk profile. It covers: your current portfolio (including MPF), age, expected retirement age, financial situation, investment objectives, investment knowledge and experience, risk tolerance and willingness to take risk — then recommends suitable funds based on the outcome. Recommending without assessing is already a breach.

What if I insist on a high-risk fund?

It must be recorded. If you’re assessed as medium-risk but insist on a high-risk fund, the intermediary must arrange an on-the-spot recording; if recording isn’t possible, their firm must arrange a recorded post-sale confirmation call, or written post-sale confirmation. This is a statutory step, not a favour.

How do I complain about a suspected rogue intermediary?

Five channels: post, email, fax, phone, or in person at the MPFA office. Provide as much as you can: personal details, the subject’s name and contacts, the complaint details, supporting material (document copies, written or email records). If misconduct is proven, the MPFA can impose sanctions: public or private reprimand, temporary or permanent de-registration, disqualification from re-registration for a period, or fines.

Does the 2012 regime still work today?

Yes — and it has only tightened since. The intermediary sales wave that “semi-portability” unleashed was exactly what this conduct regime was built for. Remember the three red flags: selling without assessing, refusing to record, no registration — any one of them means walk away.