As announced on 8 Jan 2019, SFC reprimanded and fined FWD Life Insurance Company (Bermuda) Limited (FWD Life) $2.4 million for failures in complying with the key personnel requirements under the SFC Code on MPF Products and the Fund Manager Code of Conduct.
FWD Life (licensed for RA9) failed to ensure there were at least 2 key personnel who met the minimum 5-year investment experience requirement in managing retirement funds or public funds under the MPF Code at all times.
Specifically, from Dec 2012 to Nov 2016, FWD Life had only one key personnel in place who met the minimum investment experience requirement. FWD Life only discovered it had insufficient key personnel when MPFA made enquiries in Jan 2017.
FWD Life also failed to implement policies and procedures for the designation and monitoring of key personnel and to communicate to relevant staff members of their designation as key personnel. FWD Life's failure in this respect contributed to the duration of its breach of the MPF Code.
Whenever a management member (no matter RO/MIC/director/key personnel) is going to leave a licensed corporation, a compliance officer should naturally check if the minimum threshold will be breached and then alert the senior management. This is a basic duty.
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