信托新规对理财子公司与信托公司合作模式的影响

Core Viewpoint - The release of the "Asset Management Trust Management Measures (Draft for Comments)" marks a comprehensive update to the existing trust regulations and is a significant regulatory framework for the trust industry to implement the 2018 "Guiding Opinions on Regulating Financial Institutions' Asset Management Business" [1][2] Summary by Relevant Sections Regulatory Background - Since the introduction of the asset management new regulations in 2018, supporting implementation details have been issued in various sectors, but the trust sector has lagged behind in establishing corresponding rules [2][3] - The new measures aim to transition from a patchwork regulatory approach to a comprehensive system that addresses the classification of trust business and strengthens full-process supervision [2][3] Changes in Trust Asset Management Products - As of Q3 2025, the scale of asset management products in the top ten holdings of wealth management products reached 3.63 trillion yuan, with trust plans leading at 2.65 trillion yuan, accounting for 73% [3][32] - The new regulations will require a shift in the cooperation model between wealth management subsidiaries and trust companies, emphasizing the need for diversified investment and risk management [3][4] Investment Limits and Diversification - The new measures stipulate that individual investors cannot invest more than 50% of the actual trust scale in the same trust product, and institutional investors are limited to 80% [4][33] - For open trust products involving non-standardized debt assets, the total investment from a single asset management product manager cannot exceed 50% of the trust product's actual scale [4][33] - The regulations also mandate that investments in the same asset or asset management product cannot exceed 25% of the trust product's actual scale, promoting a diversified investment approach [6][35] Reduction of Nested Structures - The measures reiterate the prohibition of excessive nested structures, allowing only one layer of investment in asset management products, with strict limits on the number of investors [9][37] - This aims to prevent regulatory circumvention through complex product structures and to ensure transparency in investment practices [9][38] Responsibilities of Trust Companies - Trust companies are required to actively manage investments and are liable for losses if they fail to fulfill their duties, adhering to the principles of "seller responsibility, buyer risk" [11][39] - The new regulations emphasize the independence of trust assets and the limited liability of trust companies, ensuring that they are accountable for their management practices [11][39] Future Cooperation Dynamics - The relationship between wealth management subsidiaries and trust companies is expected to evolve from a simple funding channel to a strategic partnership focused on product innovation, valuation, and compliance [28] - This shift will require both parties to enhance their professional capabilities in risk management and regulatory compliance to adapt to the new regulatory environment [28]