Legal Trends in the Private Equity Industry (July 2024/Issue 77)

2024-08-14 10:53:05 · LawBridge · Yang Chunbao Sun Zhen Li Jiaxin

Please refer to the official name of the law and regulations

Legal service updates from Yang Chunbao's lawyer team

Legal service updates from Yang Chunbao's lawyer team

1. Yang Chunbao's first-level lawyer team was re-hired as a permanent legal advisor by Shenzhen Oukejian Biopharmaceutical Technology Co., Ltd.

2. Lawyer Yang Chunbao and lawyer Ju Heng's team accepted a commission from a medical device company to provide comprehensive legal services for its targeted capital reduction.

3. Yang Chunbao's first-level lawyer team accepted a commission from a government-guided fund to conduct legal due diligence on a pharmaceutical research and development company.

Various announcements and self-regulatory measures

of the Fund Industry Association

Association's various announcements

The association issued an announcement on July 26, 2024, stating that three private equity fund managers, including Qingdao Lerong Fund Management Co., Ltd., had abnormal operating conditions and failed to submit special legal opinions in compliance with regulations within three months after the written notice was issued. The association will cancel the private equity fund manager registration of the three institutions.

The association issued an announcement on July 26, 2024, stating that the association was unable to effectively contact 12 private equity fund managers, including Qiding Fund Management (Shenzhen) Co., Ltd. The above-mentioned private equity fund managers shall submit a situation report through the AMBERS system within 5 working days from the date of the announcement. If it is not completed within the deadline, the association will be deemed to have lost contact, and it will be publicized in the column of lost contact institutions on the official website, and marked in the "Institutional Integrity Information" column. If it is still not completed after one month of publicity, the association will cancel its private equity fund manager registration.

Disciplinary sanctions of the association

The Association issued a disciplinary decision on July 5, 2024, stating that Shanghai Yishanmen Private Equity Fund Management Co., Ltd. ("Shanghai Yishanmen") is the executive partner of Ningbo Yinzhou Quantitative Hedge Investment Management Center (Limited Partnership) ("Yinzhou Quantitative"), which has external limited partners and makes external investments. Yinzhou Quantitative operates in the form of an equity fund with clear investment targets. The executive partner manages the fund and creates investment returns for the limited partners, which meets the characteristics of a private equity investment fund, but it has not been filed as a private equity fund product. Shanghai Yishanmen, as a securities private equity fund manager, participates in private equity investment operations and has problems with unprofessional operations. The Association decided to impose a disciplinary warning on Shanghai Yishanmen.

The Association issued a disciplinary decision on July 26, 2024, stating that Hainan Zhuozhitang Private Equity Fund Management Co., Ltd. ("Hainan Zhuozhitang") had violated regulations by failing to register some fund products, operating businesses unrelated to private equity fund management, and having chaotic personnel management. The Association decided to publicly condemn Hainan Zhuozhitang and suspend the acceptance of its private equity fund product registration for twelve months.

Regulatory developments

China Securities Regulatory Commission and other departments issued "Opinions on Further Improving the Comprehensive Punishment and Prevention of Financial Fraud in the Capital Market"

On July 5, 2024, the CSRC’s official website released a notice forwarded by the General Office of the State Council on the “Opinions on Further Improving the Comprehensive Punishment and Prevention of Financial Fraud in the Capital Market” (“Opinions on Financial Fraud”) issued by the China Securities Regulatory Commission and other departments. In the part of resolutely combating and curbing financial fraud in key areas, the “Opinions on Financial Fraud” mentioned that it is necessary to strengthen the diligence and responsibility of private equity venture capital fund managers, strengthen due diligence and post-investment management of the financial authenticity of the projects invested by the funds, and prevent fraudulent behavior.

The China Securities Regulatory Commission issued the "Regulations on Information Disclosure and Information Submission Management of Private Investment Funds (Draft for Comments)"

On July 5, 2024, the China Securities Regulatory Commission issued the "Draft Information Disclosure and Submission Management Provisions for Private Investment Funds (Draft for Comments)" (hereinafter referred to as the "Draft Information Disclosure Provisions") and solicited public opinions. The draft Information Disclosure Provisions consists of eight chapters and 43 articles. The main contents are as follows: In the general provisions, it is clarified that private fund managers, custodians, and service institutions shall disclose information to investors in accordance with laws, administrative regulations, and the provisions of the China Securities Regulatory Commission, and submit information to the China Securities Regulatory Commission and its dispatched agencies and associations; it is clarified that the information disclosed to investors shall be backed up on the information disclosure backup platform designated by the China Securities Regulatory Commission. In the general provisions on information disclosure, it is clarified that the objects, content, and methods of information disclosure. In the differentiated information disclosure section, it is clarified that the differentiated periodic reporting and temporary reporting requirements for private securities investment funds and private equity investment funds and the specific arrangements for the disclosure of underlying assets; it is clarified that the audit requirements for private securities investment funds involving non-custody and the comprehensive audit requirements for private equity investment funds; it is clarified that the custodian of private securities investment funds shall review and examine the net value of the fund, as well as the investor reminder and reporting requirements when specific risks are found. In the information reporting section, the regular, temporary and special reporting requirements of managers are clarified; it is clarified that private equity fund managers should submit annual operating conditions and audited annual financial reports. In the information disclosure affairs management section, it is clarified that the establishment of information disclosure and information reporting management system, strengthening the control of undisclosed fund information, and properly preserving relevant documents and materials are required; it is clarified that the shareholders, partners and actual controllers of managers cooperate in fulfilling the obligations of information disclosure and information reporting. In the supervision management and legal liability section, it is clarified that the handling and punishment for violating the provisions on information disclosure and information reporting are punished.

The General Office of the Shanghai Municipal People's Government issued "Several Opinions on Further Promoting the High-Quality Development of Venture Capital in Shanghai"

On July 19, 2024, the General Office of the Shanghai Municipal People's Government issued the "Several Opinions on Further Promoting the High-Quality Development of Shanghai Venture Capital" (hereinafter referred to as the "Venture Capital Opinions"), which put forward several opinions on further promoting the high-quality development of Shanghai venture capital (including angel investment): First, it emphasizes the decisive role of the market in the allocation of innovation resources, and proposes to attract qualified social capital to participate in venture capital through the guidance of fiscal funds and state-owned capital, and continue to increase support for key industries such as integrated circuits, biomedicine, and artificial intelligence; Second, it proposes to give full play to the guiding role of government investment funds, including strengthening the overall coordination of various government investment funds and state-owned funds, establishing a continuous investment mechanism, Implement preferential support policies, and optimize the assessment and evaluation mechanism of state-owned capital; third, emphasize the linkage development of venture capital and multi-level science and technology financial service system, including strengthening the linkage with market segments such as the Science and Technology Innovation Board, promoting cooperation among various financial institutions, and broadening the fundraising channels of venture capital enterprises; fourth, propose to promote the synergy between venture capital and industrial and regional development, such as actively guiding the transformation of scientific and technological innovation results, establishing a government special docking mechanism, and encouraging market-oriented mergers and acquisitions in key industrial fields; fifth, emphasize strengthening talent and policy guarantees, including accelerating the gathering of venture capital institutions and talent training, optimizing the registration management of venture capital enterprises, credit environment construction, and strengthening industry self-discipline and association construction. The "Venture Capital Opinions" will be implemented from August 1, 2024 and will be valid until July 31, 2029.

The China Securities Regulatory Commission held a special symposium and proposed to vigorously develop the private equity venture capital market and cultivate more long-term funds and patient capital

Recently, Wu Qing, Party Secretary and Chairman of the China Securities Regulatory Commission, held a special symposium in Beijing with representatives of several foreign-funded securities, funds, futures and QFII institutions in China. During the symposium, all parties put forward specific opinions and suggestions on the next step of comprehensively deepening the reform of China's capital market, including vigorously developing the private equity and venture capital market and cultivating more long-term funds and patient capital, based on the business development and investment experience of domestic and foreign capital markets.

The China Securities Regulatory Commission held a special symposium on the capital market's "five major articles" in finance

Recently, Wu Qing, Party Secretary and Chairman of the China Securities Regulatory Commission, convened a special symposium on the capital market's "five major articles" in finance. At the symposium, Wu Qing emphasized that in the next step, the China Securities Regulatory Commission will further improve the inclusiveness and precision of the capital market's support for technological innovation, take multiple measures to activate the M&A and restructuring market, promote private equity venture capital funds to play a better role, and improve the multi-level market system of stocks, bonds, and futures.

CSRC approves suspension of securities lending business

From July 11, 2024, the CSRC approved China Securities Finance Corporation's application to suspend securities lending business in accordance with the law; the existing securities lending contracts can be extended, but must be settled no later than September 30. At the same time, from July 22, 2024, the CSRC approved the stock exchanges to increase the margin ratio for securities lending from no less than 80% to 100%, and the margin ratio for private securities investment funds participating in securities lending from no less than 100% to 120%.

The China Securities Regulatory Commission held a mid-year work meeting to study and implement the spirit of the Third Plenary Session of the 20th CPC Central Committee

On July 29, 2024, the China Securities Regulatory Commission held a mid-year work meeting to study and implement the spirit of the Third Plenary Session of the 20th CPC Central Committee. The meeting emphasized the need to improve the support policies for private equity and venture capital "fund raising, investment, management and exit", enhance the full-chain and full-life cycle service capabilities for science and technology innovation companies, and pointed out the need to focus on preventing and resolving risks in key areas such as private equity funds.

Industry News

According to the statistics of MAX, a private equity fund under Zero2IPO, there were 298 investment, listing and M&A events from June 29, 2024 to July 26, 2024, involving a total disclosed amount of RMB 40.51 billion. Among them, there were 205 investment events, of which 147 disclosed amount events, totaling RMB 20.449 billion; 77 M&A events, with a disclosed transaction amount of RMB 12.317 billion; a total of 16 companies went public, with a total financing amount of RMB 7.744 billion.

Typical Cases

If a private equity fund manager violates the fund contract and fails to perform the fiduciary obligation of fair distribution to investors, he shall bear the liability for breach of contract damages to investors for the amount of funds that should have been distributed but were not distributed and the loss of interest.

Case

Dispute over entrusted financial management contract between Yu and XX Co., Ltd.

[(2023) Shanghai 74 Civil Final No. 2060]

Main Facts

In February 2017, Yu signed a "Fund Contract" with C Fund Management Company and subscribed to Class A fund shares of the fund involved in the case, which was managed by C Fund Management Company, for RMB 1.5 million. The Fund Contract stipulates that: the investment direction of the fund involved in the case is to acquire the accounts receivable generated by the construction projects undertaken by the third party; the fund shares are set as equal shares, and each fund share has equal legal rights and interests; the investment period of each fund share is 18 months, and the fund share holders will be distributed with income once every 6 months. The fund manager will distribute the principal and the remaining benchmark income to the fund share holders at the end of the investment period; the performance benchmark for Class A shares with an initial entrusted capital of RMB 1 million (inclusive) to RMB 3 million is 8.5%/year; the performance benchmark for Class B shares with an initial entrusted capital of RMB 3 million (inclusive) or more is 8.8%/year; the investment period of each fund share is 18 months, and the principle of income distribution of the fund involved in the case is that the same category of fund shares enjoy equal distribution rights... If the funds in the fund account are insufficient for distribution at that time, they should be distributed to each fund share holder in proportion to the fund shares held by each fund share holder, and the difference will be distributed and supplemented at the next income distribution or when the fund is terminated. The investors of the fund involved in the case subscribed for fund shares between December 2016 and April 2017, and all the subscription funds were used to acquire the project receivables. However, in the subsequent distribution of the fund involved in the case, some investors received all the principal and income, but Yu, who was also an investor, did not receive the distribution amount calculated according to the proportion of the fund shares he held. Yu then sued the court to order C Fund Management Company to bear the liability for damages on the grounds that C Fund Management Company failed to fulfill its fair distribution obligation and damaged his legal rights and interests. The first instance court dismissed all of Yu's claims. Later, Yu filed an appeal. C Fund Management Company confirmed that there was an early distribution, but argued that it was distributed according to the order of investors' subscription time, and did not violate the provisions of the Fund Contract.

Referee's opinion

The court of second instance held that, first, according to the provisions of the Fund Contract, the main difference between the Class A and Class B shares of the fund in question is that they enjoy different performance benchmarks according to the different initial entrusted funds, but the order of income distribution is the same. Secondly, the Fund Contract stipulates that the investment period of each fund share is 18 months, while the investment direction of the fund in question is to acquire the accounts receivable generated by the construction projects undertaken by the non-party. From the above provisions, the fund in question should be a closed-end fund with a single investment direction, and the investors should exit at the same time. Finally, if the distribution is made according to the order of the time when investors purchase fund shares as stated by C Fund Management Company, it means that for the same closed-end fund, the investors who subscribed first may be allocated all the principal and income, while the investors who subscribed later will lose all the principal, which obviously violates the provisions of the Fund Contract and the principle of fair distribution. In summary, the court of second instance did not accept the defense of C Fund Management Company. C Fund Management Company violated the provisions of the Fund Contract to distribute to some investors, which damaged Yu's right to fair distribution, and C Fund Management Company should bear the liability for compensation. Ultimately, the second-instance court revoked the judgment of the first-instance court and ordered Fund Management Company C to compensate Yu for his distributable funds and interest losses.

The private equity fund actually invested in a construction project. During the fundraising process, the fund manager and the sales agent did not disclose to investors the fact that the development and construction of the underlying assets had been overdue. The performance of the investor's suitability obligations was obviously improper and they should bear the corresponding compensation liability. In the case that the investor's asset situation has not changed significantly and they voluntarily invest in products that are higher than their risk tolerance, the risk assessment being conducted a few days later than the payment of the investment funds does not affect the establishment of the risk assessment conclusion and the identification of their qualified investor status. The "Fund Contract" stipulates a return visit and the manager did not perform the relevant procedures. However, the investor did not claim to terminate the contract within a reasonable period of time and had already received the fund distribution funds. The investor has no right to claim to terminate the "Fund Contract" on the grounds that the manager did not return the visit for confirmation.

Case

Other contract disputes between Shi and a certain company, etc.

[(2024) Hu74 Minzhong No. 250]

Main Facts

On July 18, 2018, Shi transferred 5 million yuan to subscribe for the fund involved in the case. On the 20th of the same month, D Company issued a share confirmation announcement. On July 23, 2018, Shi signed the Fund Contract with the fund manager D Company and the fund custodian. The Fund Contract states that the investment method of the closed-end equity fund involved in the case is to indirectly invest in F Company by acquiring 40% of the equity of E Company, and to develop and construct the Qiantan XX-XX land project in the name of F Company. In addition, Shi also signed the "Investor Basic Information Form (Natural Person)" and "Fund Investor Risk Assessment Questionnaire", and hand-wrote the "Risk Mismatch Warning Letter Investor Confirmation (Individual)". On the 24th of the same month, D Company issued a "Fund Arrival Confirmation Letter" to Shi. When the fund involved in the case was raised, the Qiantan XX-XX land project had been delayed in commencement and completion, and the delay in completion had exceeded half a year. According to the provisions of the "Land Transfer Contract" of the Qiantan XX-XX land project, F Company should bear the liability for breach of contract. However, neither Company D nor the sales agency Company G disclosed the above facts to investors. On July 31, 2018, Company F used the Qiantan XX-XX plot of land as collateral to obtain a bank loan. In March 2020, Company D disclosed the above situation in its 2019 Annual Management Report. In April 2020, the Qiantan XX-XX plot project was completed. In April 2021, Company D issued a postponement notice because the assets of the fund involved in the case had not been fully realized. In June 2022, Company D issued a liquidation notice stating that since the fund involved in the case had not completed the realization of all assets during the duration and extension period, the manager decided that the fund involved in the case would enter the liquidation period. Since the underlying assets of the fund were mortgaged in 2018 to apply for a bank loan, the bank has filed a separate lawsuit to obtain priority repayment for the mortgaged real estate. Shi was facing investment losses, and requested the court to order Company D to compensate him for the principal and interest losses on the grounds that the manager's risk assessment time was later than the transfer investment time and did not fully disclose to him the overdue completion of the underlying assets before his investment. The court of first instance held that although the underlying project was completed overdue, the project acceptance was still completed, and the failure of D Company to disclose relevant information in a timely manner may affect investors' investment decisions and expectations, but it was not the direct and fundamental cause of Shi's investment losses. In the end, the court ordered D Company to bear 20% of Shi's losses. Shi was dissatisfied and filed an appeal, and at the same time, he claimed that the manager had not conducted a return visit as agreed in the fund contract.

Referee's opinion

After trial, the second-instance court held that regarding the risk assessment of Mr. Shi. There is no evidence in this case that Mr. Shi had major changes in his assets from the time he paid the investment to the days before the risk assessment, or other circumstances that caused his qualified investor qualifications to change. Moreover, as a person with full civil capacity, Mr. Shi, after having paid the investment and confirmed the share, hand-wrote the "Risk Mismatch Warning Letter Investor Confirmation (Individual)", clearly stating that he was willing to invest in products that were higher than his risk tolerance and that he was willing to bear the consequences. Therefore, the risk assessment time in this case was several days later than the share confirmation, which did not affect the establishment of the risk assessment conclusion and the identification of Mr. Shi's qualified investor status.

Regarding the follow-up visit. The original intention of setting up the "investment cooling-off period" and "follow-up confirmation" clauses in the fund contract is to protect the legal rights that investors should enjoy, rather than to give investors the right to terminate without being restricted by time and conditions. In this case, Shi should have clearly known that the fund manager invested his subscription money into the fund for investment operation without a return visit to confirm success. If he claimed the right to terminate and demand the return of the investment money, he should have exercised his rights within a reasonable period after receiving the letter. However, Shi did not claim the termination of the contract, and before the lawsuit in this case, he also received the distribution money of the fund involved in the case twice. Now Shi claims the return of the investment money on the grounds of no return visit, which obviously exceeds the reasonable period and is not supported.

About the disclosure of the overdue completion of the underlying assets. The Fund Contract in this case clearly stipulates that the fund will eventually invest in the development and construction of the XX-XX plot in Qiantan, and when the fund was established, the plot had been overdue for eight months. The development and construction of the plot involves the value and risk of the underlying assets of the fund product, which has an important impact on the investment decisions and investment expectations of investors. Therefore, during the fund raising and sales stage, the manager should truthfully disclose the overdue completion to investors. However, during the sales process of the fund involved in the case, Company D and Company G did not disclose to investors the fact that the development and construction of the underlying assets had been overdue. The performance of the investor's suitability obligations was obviously improper, and they should bear the corresponding compensation liability.

In summary, the second-instance court held that Shi's appeal that Company D and Company G did not disclose to him that the project land had been overdue when selling fund products and violated the suitability obligations was established, and the rest of the appeals were insufficient. When the fund product in this case was established, the underlying assets had already shown risks, which had a great impact on the investment decisions and expectations of investors. Based on this, combined with the fact that the project land was finally completed and accepted, as well as the exit method agreed by the fund involved in the case, the causal relationship between the overdue completion and the investor's losses, etc., the second-instance court revoked the original judgment and ordered Company D to compensate Shi for 60% of his principal loss and the loss of funds occupied. As a sales agency, Company G should bear joint and several liability for the above-mentioned compensation obligations of Company D.

Regarding due diligence on fund investment projects, it is difficult to determine that the fund manager is not familiar with product information when the fund product investment structure is in line with the fund contract. Regarding whether the subject and standard of fund product risk rating are inappropriate, it should be determined comprehensively based on relevant regulatory provisions, product characteristics and product market environment. The mismatch of risk levels in different periods is not sufficient to prove that the manager improperly assessed the product risk level when the fund was established.

Case

Private equity contract dispute between Bai and a certain company

[(2024) Hu74 Minzhong No. 331]

Main Fact

On May 21, 2015, Company A signed the Investor Rights Agreement with Company H and Jia et al., stipulating that Company A would provide loans to Company H, and investors could choose to redeem or convert the loans after maturity. On the same day, Company A signed a loan contract with Company H et al., and Company Z and its actual controller Jia et al. provided joint and several guarantees for the repayment responsibility (“XX Financing Project”). On the 26th of the same month, Company X and Company Y et al. jointly signed the “First Restatement and Amended Partnership Agreement of Company A” (“Partnership Agreement”), stipulating the establishment of Company A, with Company X as a limited partner and Company Y as a general partner, and that the capital contributions of all partners should only be used to participate in XX Financing Project. On the same day, Bai et al. filled out the “Risk Testing Letter” provided by Company X, and signed the “Fund Contract” with Company X et al. The Fund Contract stipulates that the funds raised by Fund B invested by Bai are mainly used to invest in the limited partnership property shares of Enterprise A, which has the characteristics of medium risk and medium return; the "Risk Disclosure Content" states that during the term of Fund B, fund unit holders will face liquidity risks caused by the inability to withdraw funds and the risk that the entrusted funds cannot be withdrawn on schedule. Company X is the manager of Fund B. On the same day, Bai paid the investment. In February 2017, Company X issued a "Redemption Notice" to Company Y. In March 2017, Company X and the remaining limited partners of Enterprise A issued a "Disposal Instructions on the Investment of Enterprise A in a Certain Financing Project" to Company Y, requesting that a loan early redemption notice be issued to Company H. In April 2017, Company A issued a "Redemption Notice" to the borrower Company H and the guarantor, requiring each borrower and guarantor to return all principal and interest of Company A. Later, Company A sued Company H, Jia, and Company Z for the repayment of the overdue principal and interest, overdue interest, etc. The court ruled in favor of the repayment of part of the overdue principal and interest, overdue interest, etc. In August 2017, Company X sued Enterprise A, Company Y, etc., and requested to confirm that the Partnership Agreement signed between Company X and Company Y had been terminated, and to return the investment funds and investment income. The court of first instance ruled to dismiss Company X's claim. The court of second instance dismissed the appeal and upheld the original judgment. Company X had disclosed and explained the reasons for choosing the basis of the claim to investors such as Bai through work briefings before the above-mentioned lawsuit, and investors such as Bai did not object. Later, Bai faced investment losses, and sued the court for Company X to compensate for his investment principal loss and capital occupation loss on the grounds that Company X did not conduct due diligence on the investment targets of Company A during the investment stage. The court of first instance ruled to dismiss Bai's lawsuit, and Bai appealed, and claimed that Company X did not rate the B fund product, misleading him to make a wrong investment decision.

Referee's opinion

The second instance court held that, regarding due diligence. Company X and Company Y established Company A, and Company A signed a "Loan Contract" with Company H, and signed an "Investor Rights Agreement" with Company H and Jia, etc., stipulating that investors can choose to redeem or convert after the loan expires. The "Fund Contract" stipulates that after Fund B raises funds to invest in Company A, it mainly invests in convertible bonds through Company A. Therefore, the investment structure of the fund product complies with the provisions of the "Fund Contract", and it is difficult to say that Company X does not understand the product information. Under this premise, Bai claimed that Company X must prove the fulfillment of its due diligence obligations, disclose due diligence reports to investors, and disclose investment project transaction documents to investors during the fund raising stage, but there is no clear contract and legal basis.

Regarding risk rating. The product risk level is a relatively intuitive information about product risks provided by financial institutions to investors. If the product risk level is inappropriate, it will indeed lead to insufficient disclosure of product risks. However, whether the subject and standard of risk rating are improper should be determined based on relevant regulatory provisions, product characteristics and product market environment. According to the regulatory provisions at the time of the issuance of Fund B, the manager has the right to self-determine the risk rating of the fund product. Company X described the product as "medium risk" in the Fund Contract involved in the case, and there is no clear evidence that there is an improper rating. In June 2017, the Association issued the "Guidelines for the Implementation of Suitability Management of Investors of Fund Raising Institutions (Trial)", and Fund B changed its risk level to "R5" according to the guidelines. When Fund B was established, there was no relevant major negative information in the market, and when it was changed to the "R5" risk level, the financing projects and market environment of the company had changed, and the risk levels in different periods did not correspond, which was not enough to prove that the manager improperly assessed the product risk level when the fund was established.

In the end, the second-instance court rejected the appeal and upheld the original judgment.

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Read The Whole Passage

Legal Trends in the Private Equity Industry (July 2024/Issue 77)

UDF-Space · Yang Chunbao Sun Zhen Li Jiaxin

2Months Ago

Please refer to the official name of the law and regulations

Legal service updates from Yang Chunbao's lawyer team

Legal service updates from Yang Chunbao's lawyer team

1. Yang Chunbao's first-level lawyer team was re-hired as a permanent legal advisor by Shenzhen Oukejian Biopharmaceutical Technology Co., Ltd.

2. Lawyer Yang Chunbao and lawyer Ju Heng's team accepted a commission from a medical device company to provide comprehensive legal services for its targeted capital reduction.

3. Yang Chunbao's first-level lawyer team accepted a commission from a government-guided fund to conduct legal due diligence on a pharmaceutical research and development company.

Various announcements and self-regulatory measures

of the Fund Industry Association

Association's various announcements

Disciplinary sanctions of the association

Regulatory developments

China Securities Regulatory Commission and other departments issued "Opinions on Further Improving the Comprehensive Punishment and Prevention of Financial Fraud in the Capital Market"

The China Securities Regulatory Commission issued the "Regulations on Information Disclosure and Information Submission Management of Private Investment Funds (Draft for Comments)"

The General Office of the Shanghai Municipal People's Government issued "Several Opinions on Further Promoting the High-Quality Development of Venture Capital in Shanghai"

The China Securities Regulatory Commission held a special symposium on the capital market's "five major articles" in finance

CSRC approves suspension of securities lending business

The China Securities Regulatory Commission held a mid-year work meeting to study and implement the spirit of the Third Plenary Session of the 20th CPC Central Committee