Briefing on Market Entry of Foreign-invested Fund Management Company

文章摘要 本文针对外资基金管理公司进入中国市场的法律框架与实务要点进行了系统梳理。核心法律观点包括:依据《外商投资法》及《证券投资基金法》,外资基金管理公司可通过设立外商独资或合资企业形式申请公募或私募基金管理人资格,需满足注册资本、人员资质、内控制度等硬性要求。监管机构(中国证监会及基金业协会)对跨境资金流动、投资范围、信息披露等实施严格审查。实务要点强调:外资机构需提前规划股权架构,关注负面清单限制(如特定领域禁止投资);申请过程中需提交详尽商业计划书及合规承诺;取得牌照后需持续遵守反洗钱、投资者适当性管理等规定。此外,文章指出QDLP/QDIE等试点政策为外资提供了灵活路径,但需注意各地监管差异。总体而言,外资准入条件逐步放宽,但合规成本与本土化适配仍是关键挑战。

Preface


Before China’sentry into WTO in 2001, the accumulated equities or interests owned by foreign investorsin securities investment fund management company, directly or indirectly, mustnot exceed 33%; and, it is committed by China that such ratio can be capped to49% within 3 years upon China’s entry into WTO. In December 2002, the firstSino-foreign securities investment fund management company of China, ChinaMerchants Fund Management Co., Ltd. was established, the shareholding structureof which is: 33.4% by China Merchants Bank; 33.3% by China Merchants SecuritiesCo., Ltd. and 33.3% by ING Investment Management B.V.


It has been 15years since China’s entry into WTO, is there any breakthrough on the shareholdingor interest ratio of foreign investors in securities investment fund managementcompany? And, are there any relevant restrictions on foreign-invested equityinvestment fund management company?  Wetry to restore the changes and developments on market entry of foreign-investedfund management company since China’s entry into WTO hereunder.  Given that domestic public fund can onlyinvest in securities while private fund mainly invests in securities and/orequity, we intends to take foreign-invested securities investment fundmanagement company and equity investment fund management company as thesubjects of research.


1.      Securities Investment Fund ManagementCompany (hereinafter referred to as “Securities Fund Company”)


Either in accordance with the WTO commitment of China, or, relevant lawsand regulations including but not limited to: Securities Investment Fund Law of China (herein referred to as “Fund Law”), Catalogue of Industries for Guiding Foreign Investment and Administrative Measures on SecuritiesInvestment Fund Management Companies (hereinafter referred to as “Administrative Measures”), the shareholding ratio of foreigninvestment in Securities Fund Company is restricted to be capped at 49%.  Therefore, for many years, overseas institutionsin practice have had to only hold equity interest in Securities Fund Companyinstead of realization of control, as a result of which the volume of foreigninvestment into China’s securities market has been to some extent limited.However, there happened two cases recently which seems to indicate that, theshareholding ratio of foreign investment in public and private Securities Fund Companiesis expected to be broken through.


1.1             Public Securities Fund Company


Under the tenth Supplementary Agreement of Closer Economic PartnershipArrangement (hereinafter referred to as “Agreement 10”) which was mutually promulgated by Ministry ofCommerce and Financial Commission of Hong Kong Special Autonomous Region (“HKSAR”) and formally implemented on June 01, 2016, the establishment ofSecurities Fund Company controlled by HKSAR investors is permitted.  In Accordance with Schedule 1 “Detailed Commitments of Mainland to HKSAR regarding Openingup on Service and Trade” under Agreement10, fund management company invested by HKSAR financial institution canonly be joint venture and, the number of Sino-HKSAR fund companies invested byHKSAR financial institution shall be referred to the national treatment of atmost two invested fund companies in which there can only be one controlled fundcompany.  Such policy swept the legalbarriers for the establishment of Securities Fund Company controlled by HKSARinvestors, and Hang Seng Qianhai Fund Management Co., Ltd (hereinafter referredto as “Hang Seng Qianhai”) has been the first Securities Fund Companycontrolled by HKSAR investors upon the implementation of Agreement 10. The establishment of Hang Seng Qianhai was approvedby China Securities Regulatory Commission (hereinafter referred to as “CSRC”)under its Reply to the Approval on theEstablishment of Hang Seng Qianhai Fund Management Co., Ltd. promulgated onJune 16, 2016.  The approved registeredcapital of Hang Seng Qianhai is RMB 200 million, in which Hang Seng Bank(HKSAR) contributes RMB 140 million while Shenzhen Qianhai Financial Holdingcontributes RMB 60 million with the contribution ratio of 70% and 30%respectively.  The business scopeincludes fund raising and sales, asset management for specific customers, assetmanagement and the other businesses permitted by CSRC.  Hence, the first public Securities Fund Companycontrolled by foreign investors has come into being.


1.2         Private SecuritiesFund Company


In accordance with Fund Lawpromulgated in 2003, securities investment fund only includes public securitiesinvestment fund; while upon the first revision in 2012, private securities fundhas been included in the scope of regulation of Fund Law and there is a separate chapter of detailed provisionsregarding private securities fund. Meanwhile, as Fund Law is the upper law of AdministrativeMeasures, we understand that Private Securities Fund Company shall beincluded in the scope of regulation of AdministrativeMeasures which means the establishment of Sino-foreign Securities Fund Companyshall meet the restriction of foreign shareholding ratio under Administrative Measures.  However, there ushered in breakthrough inShanghai Free Trade Zone last year.


As one of the contents of SeventhSino-British Economic and Finance Dialogue, China committed in the outcome of Dialogueon September 21, 2015 that those qualified wholly-owned or Sino-foreign privatefund management institutions incorporated in China can operate privatesecurities fund management business including the securities transaction in thesecondary market. In the same month, the largest public investment fund of UK,Aberdeen Asset Management Plc’s (hereinafter referred to as “Aberdeen Asset”)acquired the business license of wholly foreign-owned enterprise issued by FreeTrade Zone Branch of Shanghai Industrial and Commercial Bureau to be permittedto establish a wholly foreign-owned enterprise Aberdeen Investment Management(Shanghai) Co., Ltd (hereinafter referred to as “Aberdeen Investment”) inLujiazui Area of Shanghai Free Trade Zone. The business scope of AberdeenInvestment includes investment management, investment consultation, investmentmanagement consultation, business information consultation, enterprise managementconsultation, international economic information consultation.  According to Aberdeen Asset, the business ofAberdeen Investment will focus on secondary market investment.  Therefore, Aberdeen Investment has been thefirst wholly foreign-owned Private Securities Fund Company in China.


2.      Equity Investment Fund ManagementCompany (hereinafter referred to as “Equity Fund Company”)


In accordance with Regulations onAdministration of Foreign-Invested Venture Capital Enterprises promulgatedby Ministry of Commerce, foreign investors are able to make equity investmentor be entrusted to manage new ventures in domestic China by establishment of Sino-foreignor wholly foreign-owned venture capital enterprise or venture capitalmanagement enterprise. Furthermore, China’s WTO commitment and relevant lawsand regulations relating to fund industry only set restriction on foreignshareholding ratio of Securities Fund Company; therefore, we understand that thereshall not be any legal barrier for the establishment of Equity Fund Companycontrolled by or wholly owned by foreign investors.


In addition, although there has not yet promulgated national laws and/orregulations relating to the establishment of foreign-invested equity investmentfund and Equity Fund Company, most of the relevant policies consecutivelypublished by Tianjin, Shanghai, Shenzhen, Xinjiang and some other localgovernments are taking an positive attitude towards the establishment offoreign-invested equity investment fund and Equity Fund Company. For example, Shenzhenhas set up working group to be responsible for the approval on theestablishment of pilot foreign-invested equity investment enterprises, toprovide one-stop services for the applicants which means by only applying once,the applicants will be able to enjoy such one-stop services including foreignexchange settlement, foreign investment approval, AIC registration, access to Qianhai,bank trusteeship, etc. And for Tianjin,Tianjin Free Trade Zone supports the normative and innovative development offoreign-invested equity investment fund, the improvement of foreign capitalsettlement and the new mode of investment fund management; it also encouragesforeign-invested equity investment and venture capital management institutionsto initiate and manage RMB equity investment funds and venture capitalfunds.  As to Shanghai, it has releasedpolicies to broaden the scope of pilot Qualified Foreign Limited Partner (“QFLP”)to attract overseas angle investors, venture capitals, equity investment funds whichown rich experiences in investment of scientific and technological enterprises,to involve in the pilot; and, the sources and using channels of fund have alsobeen broaden under such policies.


Closing


It is disclosedby CSRC that there had been 101 domestic public fund companies by March of 2016,among which 45 are joint ventures and only 17 of them are with 49% foreign shareholdingratio. And, according to the statistics of Asset Management Association ofChina (hereinafter referred to as the “Association”) by June 24, 2016, among24,431 private fund management operators, there are only 228 joint ventures andwholly foreign-owned enterprises, less than 1% of the total registered operators.


However, in accordance with Tenth Questions and Answers relating toPrivate Fund Registration and Filing (hereinafter referred to as “Q&A 10”) promulgated by the Associationon June 30, 2016, those qualified wholly foreign-owned and Sino-foreignsecurities fund management institutions will be able to operate privatesecurities fund management business in domestic China upon the approval of CSRCas well as being registered as private securities fund operator with theAssociation. The release of Q&A 10has implemented China’s commitments in the outcome of Seventh Sino-BritishEconomic and Finance Dialogue and has provided detailed operating proceduresfor the engagement of private securities fund management business by whollyforeign-owned or Sino-foreign private securities fund company; therefore it canbe predicted that Aberdeen Investment and the other foreign-invested privatesecurities fund company will be registered as private securities fund operatorsin the future.


In summary, inspite of a series of encouraging policies released recently by the regulatorsof China, the proceeding on the development of market entry of foreign-investedfund management company has proved to be relatively slow on the whole sinceChina’s entry into WTO 15 years ago.  Therefore,it is strongly suggested that the relevant legislations shall be strengthenedto accelerate the opening up, thus to introduce into the advanced managementexperience from abroad to better boost China’s fund industry.

最后更新:2018年9月2日

杨春宝一级律师简介

杨春宝一级律师,大成上海高级合伙人、资本市场部主任、国资基金研究中心主任,大成中国区私募基金专业带头人、科技与文化法律研究中心联合牵头人。执业30余年,长期从事私募基金、投融资、并购重组法律服务,尤其对对赌研究颇深且具有非常丰富的实战经验,并专注于金融机构股权投资业务。2004年起多次入选The Legal 500"私募基金"和"公司与商业"等境内外各类律师榜单,代理的中国法院首例适用外国法律审理外国公司的董事损害小股东权益纠纷案入选上海高院发布的《上海法院域外法查明典型案例》和威科先行"要案头条"。具有上市公司独立董事任职资格,系多家知名高校的兼职教授或兼职研究生导师及上海市商务委跨国经营人才培训班讲师。出版《私募股权投资基金风险防控操作实务》等16本投融资法律专著。了解更多

常见法律问题

外资基金管理公司在中国设立公募基金需要满足哪些基本条件?

根据《证券投资基金法》及证监会规定,外资机构需具备以下条件:注册资本不低于1亿元人民币且为实缴货币资本;主要股东具有从事资产管理业务5年以上经验且最近3年无重大违法违规记录;公司治理结构健全,风险控制制度完善;取得所在国监管机构颁发的合格资质。此外,需通过中国证监会审批,并遵守《外商投资准入特别管理措施(负面清单)》中的相关限制。

外资私募基金管理人登记与内资有何不同?

主要差异在于:外资机构需额外提交境外股东及实际控制人资质证明、所在国监管机构出具的合规意见函;注册资本需为实缴且不低于1000万元人民币(内资无强制要求,但需满足运营需要);投资范围可能受限于跨境资金流动规则,如不得直接参与境内二级市场特定品种。此外,外资私募基金需通过基金业协会登记,并承诺遵守《私募投资基金监督管理条例》中关于跨境投资的信息披露要求。

QDLP(合格境内有限合伙人)试点对外资基金管理公司有何意义?

QDLP试点允许外资基金管理公司在境内募集资金投资于境外市场,是外资进入中国市场的灵活路径。其意义在于:无需申请公募牌照即可开展业务,降低准入门槛;可投资境外股票、债券、衍生品等多元化资产,满足高净值客户需求;试点城市(如上海、深圳)提供简化审批流程及税收优惠。但需注意,QDLP基金额度受限于国家外汇管理局批准的总额度,且需定期报告资金投向。

外资基金管理公司如何应对中国反洗钱合规要求?

外资机构需严格执行《反洗钱法》及中国人民银行相关规定:建立客户尽职调查制度,识别最终受益人;对高风险客户(如政治人物)实施强化审查;设置反洗钱监测系统,报告大额及可疑交易;定期开展员工培训。由于跨境业务涉及多国监管,外资公司应确保其全球反洗钱政策与中国要求衔接,避免信息隔离或数据跨境传输违规。证监会和基金业协会将重点检查反洗钱内控制度执行情况。

以上内容仅供参考,不构成法律意见。如需专业法律服务,请联系杨春宝一级律师:chambers.yang@dentons.cn

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