Concerning the current remote working and work-from-home situation, the HKMA and SFC have recently responded to our proposal regarding alternative approaches in complying with Voice Recording requirements.
To summarise, the HKMA and SFC (“The Regulators”) are supportive of the proposal that under the work-from-home mode of operation where voice recording is not immediately feasible at the point of sale, intermediaries may, as soon as practicable, either call back to the bank’s telephone recording system to record the time of receipt and details of the order taken, or send an email using an office email account to the client to record the time of receipt and details of the order taken.
The Regulators have also clarified that the records of the sale process including the disclosure made at the point of sale can be kept on a telephone recording system or in other forms (e.g., on written documents).