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Conduct Requirements
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1. How to determine that an instruction to a registered intermediary has been carried out promptly under item III.18 of the “Guidelines on Conduct Requirements for Registered Intermediaries”?
Where a registered intermediary, in the course of conducting a regulated activity, takes all reasonable steps to carry out instructions promptly and accurately and informs clients that the form(s) will be passed to the relevant trustee within a reasonable specified period of time and that this timeframe is subsequently met, then item III. 18 of the Guidelines 
may generally be considered as being satisfied.
The registered intermediary should exercise reasonableness in determining the ""specific period of time"" in order to ensure that client instructions are carried out ""promptly"". The key is to keep clients informed and to ensure that the spirit of this Guideline is followed.
may generally be considered as being satisfied. The registered intermediary should exercise reasonableness in determining the ""specific period of time"" in order to ensure that client instructions are carried out ""promptly"". The key is to keep clients informed and to ensure that the spirit of this Guideline
is followed.2. Does a registered intermediary need to exercise extra care and provide additional support to an elderly scheme member as to whether, when or how much of his/her accrued benefits are to be withdrawn?
In general, subsidiary intermediaries should exercise extra care and provide additional support in advising elderly scheme members who may not be able to make an independent decision on whether, when or how much of his/her accrued benefits are to be withdrawn. Principal intermediaries should develop appropriate procedures to deal with elderly scheme members for their subsidiary intermediaries to follow.
3. If the withdrawal by instalments involves guaranteed funds, what should a registered intermediary do?
The registered intermediary should follow the relevant requirements in items III.19, III.44, III.49 and III.50 of the Guidelines on Conduct Requirements for Registered Intermediaries and draw the scheme member’s attention to the possible impacts of withdrawal by instalments from the guaranteed funds.
and draw the scheme member’s attention to the possible impacts of withdrawal by instalments from the guaranteed funds.4. Does a registered intermediary need to conduct a suitability assessment when carrying on regulated activity for a scheme member in relation to whether, when or how much of his/her accrued benefits are to be withdrawn?
As the withdrawal decision may have materially adverse consequences for a scheme member, if such decision does not suit his/her personal circumstances and the scheme member who without the relevant knowledge may rely on his/her subsidiary intermediary for professional advice, therefore principal intermediaries should develop appropriate suitability assessment procedures and internal guidelines for their subsidiary intermediaries to follow.
