Copilot GPT-5 summary and visual compliance checklist of the "SFC Handbook for Unit Trusts and Mutual Funds, Investment-Linked Assurance Schemes and Unlisted Structured Investment Products".

Copilot's recent upgrades provides a variety of useful tools for the Compliance researcher not only in regulatory intrpretation, summary, or graphical representation of complex requirements, but also can be used to provide data for re-interpretation or reconstruction into useful resource for the in-house practitioner or for business usage.

The following query to Copilot's GPT-5 mode is a case in point.

Running a query to summarise at a high level the Code in question produced the following results:

Purpose & Scope

• Issued by Hong Kong’s Securities and Futures Commission (SFC).

• Sets the regulatory framework, codes, and guidelines for:

• Unit trusts & mutual funds

• Investment-linked assurance schemes (ILAS)

• Unlisted structured investment products (SIPs)

• Aims to protect investors, ensure transparency, and maintain market integrity.

Structure of the Handbook

1. Overarching Principles – universal standards for all products.

2. UT Code – rules for unit trusts & mutual funds.

3. ILAS Code – rules for investment-linked assurance schemes.

4. SIP Code – rules for unlisted structured investment products.

5. Appendices – templates, disclosure requirements, and operational guidelines.

1. Overarching Principles

• Act honestly, fairly, and professionally.

• Ensure clear, accurate, and fair disclosure.

• Protect client assets & manage conflicts of interest.

• Maintain ongoing monitoring, complaint handling, and investor education.

2. Code on Unit Trusts & Mutual Funds (UT Code)

• Authorization: SFC approval process, eligibility of trustees/custodians, and management companies.

• Operations: valuation, pricing, dealing, meetings, and fees.

• Investment Restrictions: diversification, derivatives use, borrowing limits.

• Specialized Schemes: e.g., money market funds, index funds, hedge funds.

• Disclosure: offering documents, constitutive documents, financial reports.

• Post-Authorization: reporting, advertising, scheme changes, mergers, terminations.

3. Code on Investment-Linked Assurance Schemes (ILAS Code)

• Only authorized insurers may offer ILAS products.

• Requirements for disclosure, cooling-off periods, fee transparency.

• Rules for guarantees, with-profits features, and discretionary benefits.

• Procedures for changes, withdrawals, mergers, and advertising.

4. Code on Unlisted Structured Investment Products (SIP Code)

• Issuer & Guarantor: eligibility and ongoing obligations.

• Product Structure: fair design, counterparty selection, collateral use.

• Offering Documents: key facts statements, risk factors, ongoing updates.

• Post-Sale: disclosure, market-making, investor inquiries, unwind rights.

📑 Appendices

• Templates for offering documents & financial reports.

• Advertising guidelines.

• Internal control requirements.

Key Takeaways

• The Handbook is a comprehensive compliance manual for Hong Kong’s public investment products.

• Balances high-level principles with detailed operational rules.

• Emphasizes transparency, investor protection, and robust governance.

Next we requested a visual compliance checklist. Unfortunately the results in this query were not satisfactory with the image filled with typos and rather simplistic.

FCJ will look at alternative options to seek to produce a working quality version which can be directly used by in-house teams accordingly.