原国泰基金研究员刘文溢离职后创业成立私募上海杏泽投资，夫妻档投向婆婆公司踩线合规红线

Core Viewpoint - The China Securities Investment Fund Association issued a warning to Shanghai Apricot Capital due to insufficient disclosure of related party relationships involving its founder Liu Wenyin, who failed to adequately disclose his familial ties to a company in which the fund invested [1][4]. Group 1: Company Overview - Shanghai Apricot Capital was established on October 22, 2015, and registered as a private equity and venture capital fund manager in April 2016 [3][9]. - The company has a registered capital of 100 million RMB and a paid-in capital of approximately 32.9 million RMB, with a management scale between 2 billion to 5 billion RMB [3][9]. - Liu Wenyin holds a 46.67% stake in the company and serves as the chairman and general manager [3][9]. Group 2: Regulatory Issues - The fund "Shanghai Apricot Xinghe Venture Investment (Limited Partnership)" was registered in March 2017 and made an investment decision in January 2018 without disclosing that Liu Wenyin and a committee member, Qiang, are spouses, and that Qiang's mother is a shareholder and legal representative of the invested company [4][10]. - The association deemed the omission a violation of the Private Investment Fund Information Disclosure Management Measures, emphasizing that familial relationships must be fully disclosed as they significantly impact investor decisions [4][10]. - Apricot Capital argued that they had disclosed information prudently and that the familial relationship was publicly known, but the association rejected this defense, stating that public knowledge does not exempt the obligation to disclose [4][10]. Group 3: Internal Structure - The internal structure of Shanghai Apricot Capital is characterized as a "couple's operation," with Liu Wenyin as the actual controller and his spouse Qiang serving on the investment decision committee, although her name was not found in the publicly disclosed personnel list [5][11]. - Liu Wenyin previously worked as a researcher at Guotai Junan Fund from March 2011 to September 2013 before transitioning to private fund management and founding Shanghai Apricot Capital [5][11].