The council trustee: Consists of enterprise representatives, employee representatives and other natural persons.

The corporate trustee: Undertaken by a corporate institution with an independent civil legal capacity as well as civil action capacity

The provisions promulgated by the Ministry of Human Resources and Social Security acknowledge both of these types as trustee, but in practice, these two models have certain differences, which are mainly shown in:

1.Differences in governance structure: The occupational annuity council comes from inside the enterprise and exists due to the annuity plan, and there could be possible vacancies and transgressions on the part of the principal; while the corporate trustee is independent from the enterprise, and there are no overlapping responsibilities or interest between the principal and the trustee occurring.

2.Professionalism: A corporate trustee institution is a financial institution specialized in the trustee management of occupational annuity funds; while the annuity council mainly consists of enterprise representatives and employee representatives, not allowed to collect any fees, liable to cause the vacancy of professional invited personnel, and incapable of conducting professional trustee management.

3.Assumption of liabilities: When the council serves as the trustee and there arises any case in which the assumption of liabilities is necessary, each councilor has to assume the liability of joint indemnity ¨C but if so capability assumption of liabilities is very limited. Meanwhile the corporate institution¡¯s capability assumption of liabilities is significantly superior to the council trustee.

We suggest that rather than deciding for an occupational annuity council, a client should set up an internal occupational annuity management committee to supervise the external annuity managers without assuming any significant liabilities.