20 March 2001

To: All approved trustees of registered MPF schemes

Dear Sirs,

Trustee Notification on Late Payment of MPF Contributions

With the commencement of the MPF System, particularly after the 60 days permitted period, employers and self-employed persons have started remitting MPF contributions in respect of their employees and for themselves respectively. However, it is noted that some employers and self-employed persons may not fully comprehend the contribution and/or remittance mechanism in the early stages of MPF implementation. Most also do not understand the clearing and settlement requirements in respect of cheque payments and direct debit arrangements. This may have led to technical or administrative problems encountered, resulting in late payments. For instance, there may be cases where late payment of contributions has occurred because of the time lag between the remittance of contributions by the employers and self-employed persons and the receipt of such by the trustees, particularly in relation to cases involving direct debit arrangements or the mailing of cheques. There are also cases where contributions are made on time but are late in reaching the trustee. For example, an employer deposits a cheque into the trustee's bank account on or before the contribution day but due to the time required for cheque clearing, the contributions made are reflected in the employee accounts of the employer only after the contribution day. It may also take time for trustees to clear the influx of remittance statements and contributions on or around the 10th day of each month and have the information captured in their scheme administration system.

The Authority recognizes that it takes time for employers and self-employed persons to fully understand the remittance process. Therefore, when trustees give written notices to employers and self-employed persons for the purposes of section 133 of the General Regulation, they are advised to factor in the above situations and make sufficient time allowance in determining whether payments are genuinely late, before sending out the written notices. Sending out reminder notices immediately following the contribution day without taking into account the above situations would result in unnecessary enquiries and complaints from employers and self-employed persons who consider that they have made the payments on time but still received reminders from their trustees. Of course, trustees should also allow sufficient time for employers and self-employed persons, on receipt of the reminder notices, to make the contribution payments before the end of the settlement period.

Should you have any queries on the above, please do not hesitate to contact your case officer.

Yours faithfully,

(Raymond Tam)
Executive Director
Services Supervision

Last Revision Date: 17/10/2014