公募业绩基准指引点评：全链条完善基准监管，引导回归投资者利益导向

Investment Rating - The report maintains a "Positive" investment rating for the industry [10] Core Insights - The China Securities Regulatory Commission (CSRC) has solicited opinions on the "Guidelines for Performance Comparison Benchmarks of Publicly Raised Securities Investment Funds (Draft for Comments)" as of October 31, which aims to enhance the responsibility of fund managers and improve internal control mechanisms [2][7] - The guidelines consist of 21 articles divided into six chapters, focusing on general principles, benchmark standards, internal controls for managers, external constraints, supervision, and supplementary provisions [7] - The guidelines are expected to standardize performance comparison benchmarks for public funds, enhance the stability of public investment behaviors, and clarify product investment styles, ultimately guiding the industry back to its core mission of serving investors [14] Summary by Sections Guidelines Overview - The guidelines require fund managers to establish a comprehensive control mechanism for performance benchmarks, including selection, disclosure, monitoring, evaluation, correction, and accountability processes [14] - Decision-making for benchmark selection must be elevated to the management level, with management bearing primary responsibility for the representativeness and objectivity of the selected benchmarks [14] - An independent department is tasked with monitoring deviations from benchmarks, with the investment decision committee assessing the rationality of these deviations [14] External Responsibilities - The guidelines clarify the responsibilities of external institutions, such as custodians, emphasizing their supervisory roles [14] - Fund managers and sales institutions are required to present performance benchmarks alongside fund performance to facilitate investor comparisons [14] - Future evaluations and awards will consider benchmarks as a significant criterion, promoting a multi-layered defense mechanism around performance benchmarks [14] Benchmark Usage Standards - Benchmarks must accurately reflect the product's positioning and investment style, adhering to the investment scope, strategy, and proportions outlined in the fund contract [14] - Once selected, benchmarks cannot be changed arbitrarily, ensuring that products remain true to their stated objectives [14] - The calculation methods and data sources for benchmarks must be clear and transparent, with a reasonable compilation plan [14] Additional Provisions - The guidelines also address smooth transitions, the establishment of a benchmark library, and enhanced daily supervision [14] - Overall, the guidelines are expected to foster a more stable and clear investment style in the public fund sector, enhancing the value investment attributes of public funds and providing long-term stable returns for investors [14]