蹲后续！公募绩效新规有3处留白

Core Viewpoint - The new performance compensation regulation, "Guidelines for Performance Assessment Management of Fund Management Companies," has sparked significant debate within the public fund industry, indicating its profound impact on fund managers' compensation structures and performance evaluation criteria [1][22]. Group 1: Key Changes in Compensation Structure - Fund manager compensation is now closely tied to two hard indicators: whether the fund outperforms its benchmark over three years and whether the performance increase is positive [2][24]. - Absolute returns have a veto clause; if a fund incurs losses during the assessment period, salary increases are off the table [2][24]. - Specific salary adjustments based on performance metrics include: - Salary reduction of 30% or more for underperforming the benchmark by over 10% with negative performance [3][25]. - No salary increase for underperforming the benchmark by less than 10% with negative performance [3][25]. - Reasonable salary increases for significantly outperforming the benchmark with positive performance [3][25]. Group 2: Implications for Fund Managers - The regulation raises questions about the fairness of evaluating fund managers in bear markets versus bull markets, particularly regarding risk management capabilities [4][26]. - There is a potential need for supplementary rules to address the evaluation discrepancies in different market conditions, especially for managers who excel in risk management during downturns [5][27]. Group 3: Impact on Investment Strategies - The new guidelines may lead to increased herd behavior among institutions, as managers may prefer to invest heavily in benchmark index constituents to avoid underperformance [8][30]. - This could solidify the holding structure of institutions and exacerbate the herd mentality, potentially leading to collective underperformance when market conditions change [8][31]. Group 4: Value Investors' Challenges - The three-year waiting period is not considered long in value investing, but if a value-oriented fund manager's chosen undervalued sectors do not perform well over three years, their compensation is likely to decrease [10][33]. - The essence of public funds is to manage others' money responsibly, emphasizing that fund managers should not let investors bear the costs of their investment philosophies [13][35]. Group 5: Talent Mobility and Opportunities for New Managers - The new performance guidelines may lead to a talent exodus from public funds, as top managers may find the compensation structure less appealing [16][37]. - Conversely, the stringent regulations could attract a new breed of talent aligned with the long-term investment ethos of public funds, potentially benefiting the industry [18][38]. - New fund managers with less than three years of experience may find the regulations more lenient, providing them with opportunities to showcase their performance and build their reputations [19][41].