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.
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"。入选上海涉外法律人才库、上海市司法局鼎新法治人才库、上海国有企业改制法律顾问团,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
外商投资公募基金公司持股比例有何限制?
公募证券投资基金管理公司的外资持股比例限制经历了一个逐步放开的过程。传统监管规则要求外资在证券投资基金管理公司中的持股或权益比例不得超过49%,这意味着境外机构长期以来只能以参股形式进入中国公募基金市场,无法取得控制权。但根据内地与香港《更紧密经贸关系的安排》第十份补充协议,自2016年起允许港资金融机构在内地设立控股的基金管理公司,且该政策下的港资基金公司数量参照国民待遇,最多可投资两家,其中仅一家可控股。这一规定为港资控股公募基金扫清了法律障碍。实践中,恒生银行与深圳前海金融控股合资设立的恒生前海基金管理有限公司,于2016年6月获中国证监会批准,注册资本2亿元人民币,恒生银行出资70%,成为首家由外资控股的公募基金公司,其业务范围涵盖基金募集销售、特定客户资产管理等。这一案例表明,外资通过利用区域经贸安排可以实现对公募基金公司的控制权,但非港资机构仍受49%的比例限制。实务中,境外机构应结合自身注册地及战略目标,选择合适的准入路径;若计划控股,可考虑利用香港平台主体,并关注监管对股东资质、出资能力及经营记录的实质审查要求。
外商独资私募证券基金公司能否在华设立?
外商独资私募证券投资基金管理公司的设立条件是近年外资准入的重要突破点。法律层面,《证券投资基金法》在2012年修订后,将私募证券基金纳入调整范围,而规范基金管理公司的行政规章并未明确区分公募与私募,理论上外资设立私募证券基金公司也受持股比例限制。但2015年举行的第七次中英经济财金对话成果中,中国承诺允许符合条件的在华设立的全资或合资私募基金管理机构开展私募证券基金管理业务,包括二级市场证券交易。同年,英国最大公募投资机构 Aberdeen资产管理公司获得上海自贸区管委会颁发的营业执照,设立外商独资企业 Aberdeen投资管理(上海)有限公司,注册于陆家嘴区域,经营范围包括投资管理、投资咨询、企业管理咨询等,其业务重点为二级市场投资,由此成为首家外商独资私募证券基金管理公司。该案例表明,在自贸区政策框架下,外资可以突破传统比例限制,以全资形式开展私募证券业务。实务操作中,外资机构需关注管理人登记要求,包括实缴资本、从业人员资质、内控制度等条件;同时,自贸区试点政策与全国性规定存在差异,企业应确保注册地与业务开展地一致,并持续跟进地方金融监管部门的动态指引。
设立外商投资股权投资基金管理公司有何法律障碍?
关于外商投资股权投资基金管理公司,现行法律体系并未设置类似证券基金公司那样的外资持股比例上限。根据商务部颁布的《外商投资创业投资企业管理规定》,外国投资者可以通过设立中外合资或外商独资的创业投资企业及创业投资管理企业,从事股权投资或受托管理境内初创企业。中国加入WTO的承诺以及基金行业相关法规,仅对证券投资基金管理公司的外资持股比例作出限制,因此外资设立控股或全资的股权投资基金管理公司在法律层面不具有障碍。从地方实践看,天津、上海、深圳、新疆等地相继出台支持外商投资股权投资企业试点政策,态度积极。例如深圳设立专门工作组负责试点外资股权投资企业的审批,并提供一站式服务,申请人一次申请即可完成工商、外汇、税务等手续。这些政策为外资进入中国股权投资市场提供了便利路径。实务中,外资机构设立股权投资基金管理公司时,应重点关注以下环节:一是选择合适注册地以享受试点政策;二是满足各地对于注册资本、托管银行、合格境外投资者资格等具体要求;三是注意外汇登记及跨境资金流动合规;四是明确管理公司自身属于私募基金管理人时,需向基金业协会登记备案,并遵守合格投资者适当性制度。总体而言,外资在该领域享有较高的准入自由度,但运营中仍须符合中国私募基金的普遍监管规则。
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




