大成研究 | 成祥波等：公司债券受托管理人履职风险研究（一）：存续期管理履职清单

Core Viewpoint - The bond market in China is experiencing significant growth, with the total outstanding bond market size reaching 175.99 trillion yuan by the end of 2024, marking a 13.02% increase year-on-year, solidifying its position as the second largest in the world [2]. Regulatory Penalties - In 2024, there has been a notable increase in penalties imposed on securities companies related to corporate bonds, primarily due to inadequate due diligence and poor internal control mechanisms [2]. - The China Securities Regulatory Commission (CSRC) has issued over 22 penalties against securities firms for bond underwriting activities, affecting around 20 firms [2]. - The types of penalties have diversified, including warnings, orders for correction, and restrictions or suspensions of business qualifications, with the most frequent being warning letters [2]. Legal Risks and Investor Actions - Following the lawsuits against bond intermediaries, there has been a rise in bond-related false representation disputes, leading investors to seek recourse from stronger bond underwriters or trustees, especially when regulatory penalties are involved [3]. - The potential for bond defaults has led to a stable number of disputes over the past three years, with 2021 being the peak year for such cases [3]. Responsibilities of Bond Trustees - Bond trustees must adhere to various regulations, including the Securities Law, Company Law, and specific guidelines for bond issuance and management [4]. - Key responsibilities include continuous monitoring of the issuer's credit status, supervising the use of raised funds, and ensuring timely disclosure of significant events affecting the issuer's ability to repay [5][6]. Risk Classification and Management - Bonds are categorized into normal, potential default risk, and actual default categories, with trustees required to manage risks accordingly [3][19]. - For normal bonds, trustees must maintain ongoing attention to the issuer's credit status and report any significant changes [7][8]. - In cases of potential default, trustees are expected to implement risk warning measures and engage in proactive communication with investors [19][20]. Emergency Management and Reporting - Trustees are required to establish emergency management systems for handling bond default risks and to maintain a risk monitoring mechanism [17][18]. - Regular reporting to the market on trustee activities and any significant issues is mandated, ensuring transparency and accountability [18].