On 29 July 2024, the SFC launched a new online application/submission system, namely e-IP, on its Web-based INteGrated Service (WINGS) portal to facilitate new product applications, post-authorisation/registration submissions and regulatory filings of investment products (IP Submissions) to the Investment Products Division (IPD). The e-IP system serves as a portal for IP Submissions of investment products including but not limited to unit trusts, mutual funds, open-ended fund companies, pooled retirement funds, mandatory provident fund (MPF) products and investment-linked assurance schemes.
There is a three-month transition period during which the SFC continues to accept IP Submissions via existing arrangements. Starting from 30 October 2024, all IP Submissions must be made via the e-IP system.
In order to utilise e-IP, all product issuers (which are e-IP Managing Companies) should activate their e-IP Managing Company Account set up by the IPD and nominate at least one e-IP Administrator to operate the account. New product issuers should contact the IPD for the establishment of their new accounts prior to making their first product applications.
With the implementation of e-IP, existing template application forms and filing forms for IP Submissions will be replaced by smart-forms, while other confirmations and annexures remain in the format of word documents. The SFC will issue take-up letters and authorisation letters via e-IP. However, any correspondence / communications with the IPD during the vetting process will continue to be done via the existing e-mail arrangements.
The e-IP Administrators can grant permission to their staff and/or external legal advisors to make IP Submissions on behalf of the e-IP Managing Company. Such delegation can be made at the company level or product level and can be changed from time to time.
The e-IP system provides flexible fee payment options in addition to cheque payments. It also provides more flexibility with the signing of documents. The relevant signatories can either sign by physical signature or e-signature on the PDF forms generated from e-IP. Alternatively, unsigned documents can be submitted via e-IP with online confirmations from the submitter that the documents / confirmations are true and accurate.
Product issuers should get familiar with the e-IP system and can refer to the user guides (link) and online demo clips (link) on the SFC website for more details. Product issuers should review and consider their internal procedures and controls in light of the e-IP implementation, in particular, how the delegation arrangements and/or granting of access rights on e-IP should be done.
As a legal advisor, we have established an e-IP Advisory Firm Account in WINGS to provide assistance to product issuers, and we have already made IP Submissions (e.g. making new fund applications and filing of notices and offering documents) on behalf of our clients via e-IP.
