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北京赛车开奖直播网址:The New Asset Management Regulations officially landed

时间:2018/5/21 18:21:13  作者:  来源:  浏览:0  评论:0
内容摘要: On April 27, 2018, the central bank and other four departments formally issued the Guiding Opinions on Regulating the Asset Management Busi...

On April 27, 2018, the central bank and other four departments formally issued the Guiding Opinions on Regulating the Asset Management Business of Financial Institutions (hereinafter referred to as the “New Regulations on Asset Management”). Compared with the November 2017 Exposure Draft, the overall Reflected in the supervision of market expectations: extended rectification period, improved liquidity expectations, care bank financial amortization cost requirements and so on. However, there are no substantial differences between the major ones such as breaking the rigid payment, prohibiting the mismatch of deadlines, guiding long-term funds into the standardized market, and strengthening unified supervision.

First, the transition period has extended beyond the market's expectations by the end of 2020. Taking into account the longer period of non-standard assets, the transition period for its disposal is the focus of the market discussion before the new regulations are formally introduced. Compared with the consultation draft, the “New Asset Management Regulation” will extend the transition period to the end of 2020, giving financial institutions sufficient time for adjustments and transitions. It encourages institutions that have completed rectification in advance and allows financial institutions to issue docking of old products to maintain the necessary The liquidity and market stability, but said it should be strictly controlled within the overall size of the stock product, and orderly compression and decline. Of course, financial institutions should formulate rectification plans for the asset management business during the transitional period and specify time schedules, and submit them to the regulatory agencies for approval before implementation.

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Source: wind, CITIC Securities

second, breaking the rigid payment of net management relaxed refinement, clear amortized cost method and scope of supervision. The “New Assets Management Regulations” require that financial assets invested in asset management products adhere to the principle of fair value measurement and encourage the use of market value measurement. At the same time, some assets that meet one of the following conditions are allowed to be measured at amortized cost: First, the product is closed-end operation, and the financial assets invested are subject to the contractual cash flow for the purpose of holding and expire; second, the product is closed-end operation, and The invested financial assets do not have an active trading market for the time being, or there is no quoted price in an active market, or reliable valuation of fair value using valuation techniques. However, it also requires custody accounting, periodic reports, and external audit confirmation.

Third, liberalize the use of standardized assets (stocks/bonds) with fair value and good liquidity, and restrictions on the issuance of equity public offerings and other products by banks. The “New Asset Management Regulations” took full account of the market demand and affordability, set different classification ratios for products that are allowed to be graded, and relaxed the “private draft” in which investment in private investment products with a single investment target exceeded 50 percent. % is regarded as a "single" and "non-classifiable restriction on investment in bonds, stocks, and other standardized assets with a proportion of more than 50%" and "approved by the banking regulatory authorities for the issuance of equity products and other products by banks." limit.

Fourth, clarify the conditions of standardized debt assets. The “New Regulations on Asset Management” clearly defines the four core elements of standardized debt assets, ie, differentiation and tradable; 2 sufficient disclosure of information; 3 centralized registration and independent trusteeship; 4 fair pricing, perfect liquidity mechanism; Differentiated from the standard assets, we propose regulatory measures such as deadline matching and limit management, and guide commercial banks to orderly compress the scale of non-standard stocks to ensure the operability of policies.

Relaxation of some provisions of the new regulations will alleviate the impact of market sentiment after the new regulations are settled to a certain extent, but the long-term impact has just begun and the impact path is complex.

In addition, non-standard assets may face the situation that some stocks have expired and there is no increment. Many people say that non-standard items will return to the table, and the scale of credit extension will be restored and expanded. However, we hold a very cautious attitude toward non-standard return forms, and the more difficult it may be to return the form to the later stages of rectification, such as the following situations: helping commercial banks to appear badly, bypassing real estate, and investing in companies with two high and one low, around the enterprise Credit concentration, around regulatory indicators. After careful analysis, the difficulties of these non-standard return forms in these situations cannot be underestimated, and they will reach maturity or face default, which will continue to cause companies to shrink their balance sheets and cause local risk transmission.

The extension of the transition period will moderately mitigate the impact of the asset's volatility on the financial markets. However, in the areas where many potential risks exist, the process of dismantling the leverage structure and fund pool structure has gradually exposed and transmitted risk. Even if it appears to have little effect on the equity market, the actual impact is also beginning. In the contraction of the credit environment, the institutions with high leverage in the past are facing greater liquidity pressure. Passive selling of assets has also had a certain impact on the market. Typical targets such as equity pledges triggered a sell-off after the strong flat line. Even some high-quality assets may face pressure on their shareholders to deleverage, and do not rule out accidental injury.

Of course, ensuring that systemic risk does not occur is also the bottom line. In the future, if relatively high-quality assets are subject to greater impacts in Tengneo, it will also bring about some special investment opportunities. In the long run, a more standardized and net asset management industry is also positive for the stable development of the basic market. For the future investment, we need to continue to pay attention to the changes in the behavior of financial institutions after the implementation of the policy, the effectiveness of the implementation of new regulations after landing, and the changes in the orientation of some hedging policies under the “double pillar”. In the coming years, the prevention of financial risks is the top of the “three major challenges.” Preventing risks should also be a primary consideration of financial market participants.

The Innovation Business Investment Department believes that the new asset management regulations aim to guide the development of funds in the medium to long term, focus on fostering investment trust services for customer financing, and solve the mixed issues of licenses in an integrated manner. This will form a long-term foundation for the capital market. The benefits of the role, followed by the introduction of foreign capital, pension, annuity of the company's incremental funds to enter the market to create institutional conditions for the market at the bottom of the long-established, structural walk-through to create the basis.

Next, we will conduct a one-to-one analysis of the details of the new asset management regulations, including two parts and eight items. The first three items are the first part, which mainly specify the scope of application of the new regulations, the qualification requirements for organizations and business personnel engaged in asset management business, and the management methods for the asset management industry. The fourth to the eighth items are the second part, mainly clarifying the requirements of the new regulations for the entire life cycle of an asset management product “design-sales-investment operation-back-office management (including valuation)”.

(I) Scope of application: Asset management business and product redefinition Article 2: Asset management business refers to banks, trusts, securities, funds, futures, insurance Asset management agencies, financial asset investment companies and other financial institutions accept investment Investors are entrusted with the financial services to invest in and manage the assets of the entrusted investors. ......

The asset management business is an off-balance-sheet business of a financial institution. Financial institutions must not promise to protect their profits while carrying out asset management business. When there is difficulty in redemption, financial institutions may not use any form of cash advancement. Financial institutions must not carry out asset management operations within the table.


Article 3: Asset management products include, but are not limited to, non-private-branded financial products in the form of RMB or foreign currency, capital trusts, securities companies, securities company subsidiaries, fund management companies, fund management subsidiaries, futures companies, futures Company's subsidiaries, insurance asset management institutions, and asset management products issued by financial asset investment companies. The asset securitization business carried out pursuant to the rules promulgated by the financial management department is not applicable to the pension products issued pursuant to the rules promulgated by the human resources and social security department.


In summary, the new regulations have achieved the principle of asset and management integration, that is, the way of distinguishing between public offerings and private placements (special accounts) solves the capital-end problem: applicable to banks, securities companies, trusts, insurance management, funds Subsidiaries, futures and futures sub-categories issued by the seven categories of asset management products. Private equity institutions are non-financial institutions. Their fund products should first be adapted to the relevant laws and regulations of private equity funds. If there are no regulations, they will follow the constraints of the new regulations on asset management. This is different from the draft of the draft.

There are also four types of asset management products that are excluded and are not subject to the new regulations on asset management.

1. Property rights trusts. This is a kind of non-financial trust. The practice includes land transfer trusts, housing/equity holding trusts, and other property or property rights trusts (bank credit assets, small loans, etc., which are commonly used for the securitization of private assets).

The reason why it is excluded is because the property rights trust and the traditional asset management business model are the opposite. It is a process from assets to capital.

2. Guaranteed financial management. The new regulation requires that “financial institutions must not develop asset management business within the table”, and the corresponding asset management business is bank-based capital preservation management. Banking guaranteed financing is currently the only asset management product that can clearly ensure the benefits of this insurance. It will be included in the bank statement as a deposit when it is calculated. It is more like a bank that breaks through the limit of interest rate (one vote veto in the MPA assessment. The pricing act will limit deposits and loans interest rate ) The means of high interest rates are different from the source of asset management “valet management, profit and loss”, and it is reasonable to exclude them.

Future guaranteed capital management products will gradually disappear, and will be replaced by structured deposit products in the form of deposits and derivatives. In the four months during the consultation, many banks have already prepared in advance and started a large number of structured deposits. On the one hand, it is necessary to prepare for the maintenance of the asset management stage of this book, and on the other hand, it is under the pressure of lack of debt.


3. ABS (including Reits) business. This is the only one of the new rules on asset management that has been directly excluded by the “exemption clause”, and the other is the pension product. In doing so, the special asset support plan required by the ABS business is also different from traditional asset management products. It is an asset management plan for transaction management and partial investment banking; secondly, the supervisory level intends to encourage direct service. Development of the ABS business in the real economy. In addition, we have seen that the details of the exchange increased the extent of pledge of ABS and the proportion of pledged also conforms to the direction of encouragement.

4. Venture capital funds, government assets investment funds. This aspect is to encourage equity investment in the start-up phase and assist the financing of high-tech industry. On the other hand, given that most current industrial funds involve multiple levels of nesting, it is easy to source funds for infrastructure projects such as PPP if no longer specified otherwise. Constitute larger constraints.

(II) Main requirements of asset management business: financial institutions and business personnel

Article 7 paragraph 2: Financial institutions shall establish and improve qualifications, training, evaluation and accountability systems for asset management business personnel, and ensure that they are engaged in asset management. The staff of the business have the necessary professional knowledge, industry experience and management capabilities, and fully understand the relevant laws and regulations, regulatory requirements and the legal relationship of asset management products, transaction structure, major risks and risk management and control methods, and comply with the standards of conduct and professional ethics.

Article 13 Paragraph 1: Financial institutions whose main business does not include asset management business should establish an asset management subsidiary with an independent legal person status to carry out asset management business, strengthen corporate risk isolation, and temporarily set up specialized The asset management business operations department conducts business.

Article 14 (2): During the transitional period, a commercial bank with the qualifications of a securities investment fund custody business may hold the bank's wealth management products, but it should open separate custody accounts for each product to ensure asset isolation. After the transitional period, a commercial bank with the qualification of a securities investment fund custody business shall establish a subsidiary with an independent legal person status to carry out asset management business. The commercial bank may hold asset management products issued by subsidiaries, but it should achieve substantial independent trusteeship. The independent trusteeship is nominal, and the financial supervision and management department will correct and punish it.


Uniformly improve the access threshold of the asset management industry through licensing and qualifications, and let some “fake financial management” and “pseudo-funds” disappear in the market: the requirements for the development of asset management business entities are reflected in the financial Institutions and practitioners in two aspects. Regarding the requirements of employees, the new regulations do not set any specific constraints. All of them are in principle and have little impact. However, financial institutions are required to establish a training accountability mechanism for practitioners who do not comply with the principles and relevant laws and regulations. The new regulations for asset management have clarified the requirements for the requisition of punishments. The most important task is to cancel the qualifications of the employees and prohibit them from entering the asset management industry. This is much stricter than the practice of dealing with financial institutions in most of the previous irregularities. Because of the direct involvement of personal interests, this approach helps to improve behaviour that disregards professional conduct for short-term gains.

The requirements for financial institutions, "Financial institutions that do not control assets for their main business, need to establish a separate independent capital management company" indicate that there may be a license requirement for the development of asset management business. After that, they added that "there is no provision for temporarily setting up assets management." The department replaced, but the time is not clear and it remains uncertain. The relevant financial institutions need to respond earlier.

In addition, in the qualification requirements of financial institutions, it is even more important that banks with custodian assets begin to need additional capital management companies to conduct business. China Merchants Bank This matter has been put on the agenda in the 2017 annual report, and more banks will make requests in the future.

After the asset management business becomes independent, the bank will be converted into a consignment agency to develop in the direction of financial product supermarkets. Subsidiaries will concentrate on asset management operations, specialize in labor division, and systematically achieve the isolation of on- and off-balance sheet risks. It will benefit the progress and development of the asset management industry.

Through the announcement, we can see that China Merchants Bank [Llinks1] has already invested RMB 5 billion in the asset management subsidiary. In the positioning of the bank's asset management company, we believe it may be the “public fund + fund + wealth management”. The portfolio focuses on standardizing the investment in equity assets, continuing to control the retail end, common customers and high-net-worth customers simultaneously, forming a competitive landscape with the public fund fund company , and secondly, not to abandon the previously accumulated project experience and resources, and using the parent company. The company's channels, information and resources, and good non-standard financial management. The future 29 trillion yuan of bank financing will also be divided into active management mode and outsourcing mode.

Source: wind, CITIC Securities

(c) Product Management: Private points raised

Article IV Section: asset management products in a different way to raise, divided into public offering of products and private equity products. Public offerings are publicly available to unspecified people. The standards for public issuance are in accordance with the “PRC Securities Law”. Private equity products are issued to qualified investors in a private manner.

Interpretation: With respect to public offerings, the new regulations require the implementation of the Securities Act. In the securities law, it is recognized that there are three criteria for public offering: 1) the issuance of securities to unspecified objects; 2) the issuance of securities to specific objects that cumulatively exceeds 200; 3 other acts of issuance as prescribed by laws and administrative regulations.

Therefore, a simple understanding of public fund management products is in fact no specific requirements for investors, "everybody can vote", or even if the investors have specific requirements and the number of products over 200 people. Prior to this, the market has been discussing that the new regulations on asset management may require all public offerings to have the same starting sales standards, reflecting the principle of uniform supervision and fair competition for capital management (currently, the financial management is 50,000, the large collection of securities companies is 50,000, and public funds It is 1 yuan), but this point is not reflected in the article. Public funds have advantages in the starting point of investment.

The criteria for the identification of private equity products, in addition to the number of persons below 200, also require qualifications for investors, that is, require qualified investors.

Article 5: The investors of asset management products fall into two categories: unspecified public and qualified investors. Qualified investors are natural and legal persons or other organizations that have the ability to identify risks and bear risks and invest in a single asset management product that is not lower than a certain amount and meets the following conditions.

(I) Having more than 2 years of investment experience and satisfying one of the following conditions: household financial net assets of not less than 3 million yuan, family financial assets of not less than 5 million yuan, or the average annual income of not less than 3 years 400,000 yuan.

(b) The legal entity with net assets of not less than RMB 10 million at the end of the current year.

(III) Other situations that financial supervision and management departments regard as qualified investors.

Qualified investors investing in a single fixed income product amounting to not less than RMB 300,000, investing in a single mixed product not less than RMB 400,000, investing in a single equity product, a single commodity, and finance The amount of derivatives products is not less than 1 million yuan.

Investors may not invest in asset management products using non-ownership funds raised through loans, issuance of bonds, etc.


Compared with the previously non-integrated standards, the new asset management standards for qualified investors are tightened at the entry level and relaxed at the investment level: in terms of income and property requirements, 3 million assets and continuous Three years of 400,000 income, now requires 5 million but three consecutive years of 300,000 income, and two years of investment experience. In terms of subscription sales, it is good for all private equity products. Regardless of the type of products that were invested, the subscription amount must be more than 1 million. Now, depending on the investment assets, the minimum price has been reduced to 300,000 yuan.

However, the identification of household "financial net assets" is a relatively complicated task. Investors are required to truthfully disclose the family’s financial assets and total liabilities to the financing institution in order to accurately calculate and determine the amount of financial net assets. The situation of the total assets and liabilities of the natural family is more private information, and the initial implementation of fear can only rely on investors' commitments.

On the basis of the division of publicly-held private placement products, the new regulations on asset management set different investment restrictions.

Article 10 Paragraph 1 : Publicly funded products mainly invest in standardized creditor assets and listed shares. Except as otherwise provided by laws, regulations and financial management departments, they may not invest in shares of unlisted companies. Public offerings can invest in commodities and financial derivatives, but they should comply with the laws and regulations as well as the relevant regulations of the financial supervision and management department.


At this stage, the bank's public offering products are mainly fixed income products. For example, the issuance of equity products and other products is subject to the approval of the banking regulatory authority [Llinks1], except for the products used to support marketization and the conversion of legalized debt into equity. The current policy of landing represents that banks, especially those with active management capabilities, can similarly publicly raise funds to issue active equity (including FOF) products, which will increase their interim business income.

The investment scope of private placement products is stipulated in the contract, and it can be used to invest in debt assets, stocks listed on the market (listed), shares of unlisted companies (including debt-to-equity swaps) and acceptance (receiving) benefits, and strict compliance with the appropriate management of investors. Claim.

The provisions of Article 10 are relatively clear. In the scope of public investment, compared with the expression of “debt assets with low investment risk and strong liquidity” mentioned in the exposure draft, this direct description can only be used for investment in standardized credit assets and listed trading stocks. It is more explicit and non-standard. Sources of funding have further contracted. For bank financing, it can be seen that the policy has already opened the path for issuing equity public offerings.

(4) Product design requirements: simplification of grading and transaction structure

Article 21 Clause 1: Public offerings and open private placement products may not be divided into shares.


In the design of hierarchical products, the text of the new regulations has been loosened compared with the requirements of the drafts, and the restrictions on the ratio of single-standard investment to standardized products have been missing. Considering that there were more bank financing funds that entered the stock market in the form of investment-grade products, many of the trust plans were structured products that were specifically invested in the stock market. The cancellation of 50% of the ratio was more impact on the stock market than before. Small lot.

However, the new regulations for asset management pointed out that “the graded asset management products mentioned in this Article refer to the existence of a share above the first-level share that provides certain risk compensation for other levels of shares, and the distribution of income is not calculated according to the proportion of shares, as otherwise agreed by the asset management contract. "Products." This definition is the same as the definition of the classification account under the eight bottom lines of the Securities and Futures Commission. It is well-known that the eight bottom lines implemented in 2016 rely on the above provisions to completely negate the structure of credit-like products that are “after-paid as a priority, guaranteed prime income, and priority should be followed by leverage”. Since that time, the so-called structured arrangements for special accounts have experienced the same decline in shareholdings, with only proportional differences and no sequential differences.

We believe that the implementation of the new asset management regulations will not only rekindle the traditional hierarchical structure, but should also return the structured trusts and graded insurance asset management products of other financial institutions to the same track as the CSRC requires. Only follow This understanding can really help reduce the leverage of the gold financing industry and eliminate regulatory arbitrage.

Article 22(2): Asset management products may be reinvested in a layer of asset management products, but the asset management products invested may not be reinvested in asset management products other than public offering securities investment funds.


Reducing nesting and reducing idling; The current 100 trillion class asset management system contains a lot of nested moisture: The commissioning agency should carry out due diligence on the trustee organization, implement list management, and clearly specify the access of the trustee organization. Standards and procedures, responsibilities and obligations, duration management, conflict prevention mechanisms, information disclosure obligations, and exit mechanisms. The entrusted institution shall not be exempted from its own responsibilities by investing in other institutions.

Financial institutions may employ professionally qualified institutions supervised by financial supervision and management departments as investment advisors. Investment advisers provide investment advice to guide commissioning agencies.

This is another requirement for product design. It is consistent with the spirit of the exposure draft, ie, the nesting of asset management products with more than two levels (except public funds) cannot be carried out. Under this stipulation, past models such as the China Securities Exchange Bank or the Bank of China Securities will disappear. In the past, cross-departmental supervision and coordinating difficult loopholes could not be carried out, and the product trading structure will be simpler and more transparent.

For outsourcing, according to the new regulations, only the FOF model and the investment model, the nesting has a high probability to reduce at least one layer of channel.

(E) Product sales requirements: Specification of agency channels

Article 9 Paragraph 1: Financial institutions' sales of asset management products issued by other financial institutions shall meet the qualification requirements stipulated by the financial supervision and administration department. Without the permission of the financial supervision and management department, any non-financial institution or individual may not sell assets management products.


Solve the access problem from the capital side and require the sales of asset management products to have a license: In addition to the provisions on the channel, more accurate and complete products should also include the requirements for the amount of sales, but considering The amount of sales has already been described in the Qualified Investors section. We will only talk about the issues of channels here.

Public funds and trusts are different from the former two, and they are highly dependent on the agency channels. In respect of public offerings, the development in the past few years relied on the expansion of the institution-side and the improvement of the institutional sales network. However, the retail end has been relatively neglected, relying mainly on bank funds, Internet platforms and other third-party agency sales channels. Trusts are similar, mainly relying on the expansion of bank financing and channel requirements within the table. The maintenance of offline retail customers is more dependent on private banking departments and third-party agency sales platforms. Most small and medium-sized trusts want to build regional wealth. The cost of the management center is too high.

Therefore, under such a situation, the new regulation of asset management by the new regulations on agency sales channels, and the “ban of unlicensed agency agencies” will mainly affect public offerings and trusts, and only active management institutions with “wine does not care about the alley” or Unique positioning agencies can stand out. In addition, since all products will need to be valued using the net value method, all parties are on the same starting line, the collection of product funds will be intensified, the bank’s agency sales may be more biased towards its own products, and public funds will be squeezed more severely. .

(VI) Investment Operation Requirements for Products: Control Leverage, Fencing, and Non-Standard Funding Pools

Compared with the previous four items, the new regulations on investment management have more regulations and most profound impacts. The draft of the consultation is basically consistent.

1. Prohibit the use of capital pools and prohibit the non-standard period mismatches. Article 15 Paragraph 1: The financial institutions shall manage the funds of each asset management product separately, establish individual accounts, and perform accounting independently, and may not carry out or participate in rolling distributions or collections. Capital pool business that operates and separates pricing features.


Break the rigid redemption, let the funds determine the matching of the yield and the risk at the market level: the capital pool operation mode and the just-matched financial management, trust and brokerage capital management often go hand in hand. If you want to break the just-denominated, then the products operated by the fund pool model must be prohibited from clearing.

We say that the valuation of fair value, net worth products, is to make the net value of the product can reflect the changes in the value of investment assets. For example, the bond that was invested fell today, and the net value of that bond should fall as the price of bond assets falls, and vice versa.

Article 15, paragraph 3: In order to reduce the risk of maturity mismatch, financial institutions shall strengthen the duration management of asset management products, and the term of closed asset management products shall not be less than 90 days. Where an asset management product is directly or indirectly invested in a non-standardized debt asset, the date of termination of the non-standardized debt asset may not be later than the due date of the closed asset management product or the latest open date of the open asset management product.


From the definition of “non-standard” to the definition of “non-standard” to the definition of necessary conditions for standardized assets: First of all, with regard to the identification of non-standard, in the new regulation of asset management, supervision supervised the 2013 CBRC No. 8 document. From the point of view, but continued the mode of the draft of the draft, the white list was used to distinguish between standard and non-standard, that is, to give a standardized range of claims, and the rest are non-standard claims. Standardization of claims for standardization of claims is more stringent than drafts for seeking exposure. In addition to requirements for trading venues, fair value, and liquidity, information disclosure and tradeable requirements have also been added. At present, many assets that have not been identified as non-standard may be included in the future. As for the determination of the North Gold Institute and the Yindeng Center, the new regulations on asset management have still not been given.

Secondly, we still adopt a ban on unstandardized deadlines and require that the non-standard asset's due date be no later than the expiration date of the closed product or the last open day of the open product.

From the perspective of regulation and risk prevention, the requirement for misalignment of liquidity and prohibition period is a useful supplement to non-standard supervision in the early stage.

2. Separate operation from its own business

Article 13(3): Financial institutions conducting asset management operations shall ensure that the asset management business is separated from other businesses, the asset management products are separated from the financial products it sells, and the asset management products are mutually exclusive. Separation, asset management business operations and other business operations are separated.


The requirements for asset segregation represent the segregation of self-owned funds and customer wealth management, and also represent the segregation between different proxies and wealth management products. This is the content of Article 13 of the “Guiding Opinions”. The purpose is to divide the market risk and the institutional risk, similar to the 14th article on independent trusteeship and the subsequent article on breaking the rules.

One of the risks to guard against risk is the systemic risk of financial institutions as a result of the market downturn. To achieve this, in addition to strict control over self-operating, liquidity, and other issues, it is necessary to eliminate the current misuse of the boundaries between self-owned funds and capital management funds, and to ensure that funds are used to supplement capital funds. Funds and other shortcomings.

3. Leverage requirements

Article 20: The asset management product should set the upper limit of the debt ratio (total assets/net assets), and the same kind of product should apply a uniform liability ratio ceiling. The total assets of each open-ended public offering may not exceed 140% of the net assets of the product. The total assets of each closed-end public offering and each private placement product may not exceed 200% of the net assets of the product. When calculating the total assets of a single product, the total assets of the asset management product invested should be combined in accordance with the principle of penetration.


Leverage=asset/(asset-liabilities). Leverage can be divided into two types. Leverage is product design leverage (prioritized inferiority) and pledge or buyout financing leverage. These two levers have detailed descriptions in the "Guiding Opinions".总体来看,除对分级产品有全新规定外,对杠杆的要求均与内审稿、证监会发布的新八条底线以及302号文一致,即整体控制杠杆比率,统一化运作并以穿透的高标准关注资管产品投资下层产品叠加的杠杆。























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