Compliance vs Coronavirus

With the outbreak of coronavirus, the Hongkong Post has suspended office counter service, mail delivery service and mail collection from posting boxes from 29 January to 2 February 2020.  As a result, securities firms are facing the difficulty of complying with the Securities and Futures (Contract Notes, Statements of Account and Receipts) Rules (CNR)...they have failed to deliver the contract notes and statements within the statutory deadline (T+2).

If contract notes / statements could be left at the counter of Hongkong Post (with delivery delayed), then there is no problem because those mails have already been "served" (i.e. out of the securities firm's hand).  Unfortunately, now Hongkong Post's mail collection service is also halted.

Though most of the investors should have chosen the receipt of contract notes and statements by email, there is a certain demand (esp. from senior citizens) for hard copies.

In principle, securities firms may take other means (e.g. courier service) to deliver the mails, but the cost is prohibitively high.

If a securities firm fails to send out contract notes / statements timely, it should report such technical breach to SFC under s18 of the CNR within 1 business day, even though the delayed delivery is not caused by internal operational matter (thanks CCP).

Probably SFC had received too many enquiries within this week, yesterday it issued an email to inform all licensed corporations that they are NOT expected to give the s18 report where the delay is caused by the suspension of postal service.

This is "Law in the Time of Cholera" (法在瘟疫蔓延時)!