Mrs Kwok's IPS was agreed two years ago while she was working. She has now retired early after an illness and will draw on her portfolio for living costs. What should her manager do?
An IPS is reviewed on a schedule and also whenever the client's circumstances change materially. Early retirement changes Mrs Kwok's income, liquidity needs, time horizon and ability to bear risk, so the IPS must be revised now. The SFC's suitability FAQs also expect client information to be updated on a continuous basis where appropriate, and a discretionary mandate to be reviewed having regard to the client's latest circumstances. Raising cash until the annual review, updating only the questionnaire, or changing only the allocation all leave objectives and constraints that no longer fit her: the IPS itself must be revised. Source: Standard portfolio management practice (investment policy statement: objectives and constraints); SFC FAQs on Compliance with Suitability Obligations (sfc.hk, last updated 23 Jul 2026) Q2; SFC FAQs on Triggering of Suitability Obligations (sfc.hk, Dec 2018) Q3 (as at October 2026).
Assuming an IPS changes only on its review date. A material change in the client's life triggers a review at once.
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