EBSCN·2025-12-03 10:32Group 1: Report Industry Investment Rating - Not provided in the content Group 2: Core Views of the Report - On November 28, 2025, the CSRC issued the "Announcement on Launching the Pilot Program of Commercial Real Estate Investment Trusts (Request for Comments)" to solicit opinions on the pilot program of commercial real estate investment trusts. On December 1, 2025, the National Development and Reform Commission expanded the industry scope of infrastructure REITs to include commercial office facilities and urban renewal facilities, and added sub - categories such as stadiums, commercial complexes, and four - star and above hotels in consumer infrastructure [3][10][14]. - Launched during the real estate downturn, it provides an opportunity to revitalize the trillion - dollar commercial and office market. It can improve the asset structure of enterprises, help the real estate industry transform into a new development model, and enrich the types of underlying assets in the domestic public REITs market [3][10]. - It is necessary to pay attention to the institutional connection, and detailed rules are still awaited. The overall institutional framework of commercial real estate REITs follows that of infrastructure public REITs, and the specific categories and review mechanisms need further clarification. Implementing a dual - track review system may improve efficiency and accelerate market expansion. The applicability of the key expansion and recruitment mechanism and pilot tax policies in commercial REITs also needs attention [3]. - The secondary market of infrastructure public REITs is under short - term pressure. The valuation and operation quality of new products are the keys. The historical average dividend yields of Japanese office building REITs and hotel REITs are similar to those of current infrastructure public REITs equity - type products [3]. - Investment advice: In a low - interest - rate environment, high - dividend public REITs have an obvious interest - rate spread advantage. With the expansion of categories and improvement of the system, the market is expected to develop rapidly. Attention should be paid to the progress of new - category projects, products with strong underlying asset demand, and expansion and recruitment [3]. Group 3: Summary by Relevant Catalog 3.1 Public REITs Expand to the Commercial Field - On November 28, 2025, the CSRC solicited opinions on the pilot program of commercial real estate investment trusts, with the feedback deadline on December 27, 2025 [10]. - The National Development and Reform Commission is promoting the expansion of infrastructure REITs to more industries and asset types. On December 1, 2025, it issued the "List of Industry Scope of Infrastructure Real Estate Investment Trusts (REITs) Projects (2025 Edition)", expanding to commercial office facilities, urban renewal facilities, and adding sub - categories in consumer infrastructure [14]. - In Q3 2024, there were 736 five - star hotels in China, accounting for 43.5% of the operating income of star - rated tourist hotels, and 2073 four - star hotels, accounting for 37.6%. The scope of the new expansion includes commercial office facilities (super - A and A - grade commercial buildings in super - large and large cities) and urban renewal projects (old - block and old - factory renovation projects), with isolation mechanisms set up [12]. 3.2 The CSRC Solicits Opinions on the Commercial REITs Pilot - Product definition: A commercial real estate investment trust fund is a closed - end publicly offered securities investment fund that invests in commercial real estate asset - backed securities to obtain the ownership or operating rights of commercial real estate, operates and manages commercial real estate to obtain stable cash flows such as rent and fees, and distributes the main income to fund share holders [15]. - Application process: To apply for the raising of a commercial real estate investment trust fund, the fund manager should submit the registration application materials stipulated by the "Securities Investment Fund Law" and the CSRC to the CSRC [20]. - Current situation of infrastructure public REITs: The current application process is "local NDRC - national NDRC - CSRC", with a long review process and a relatively small market scale. As of November 30, 2025, the issuance scale of the public REITs market (initial offering and expansion and recruitment) was about 209.5 billion yuan, and the market value was about 219.9 billion yuan. For commercial real estate assets with a higher degree of marketization, applying only to the CSRC can shorten the review process and accelerate market expansion [25]. - The scale of China's commercial real estate is huge, about 40 - 50 trillion yuan. Some enterprises are preparing for relevant application work, such as Fosun's progress in the independent listing plan of Sanya Atlantis through the REITs model [25]. 3.3 Pay Attention to the Institutional Connection - The overall institutional framework of commercial real estate REITs follows that of infrastructure public REITs. The "Request for Comments on Commercial REITs" is more concise in terms of the requirements for fund managers and custodians, fund manager responsibilities, and asset requirements. The asset sub - types in the "List of Industry Scope of Infrastructure Real Estate Investment Trusts (REITs) Projects (2025 Edition)" are more specific [26]. - Implementing a dual - track review system for infrastructure public REITs and commercial real estate REITs can provide more choices for issuers, improve review efficiency, and accelerate market expansion. The applicability of the expansion and recruitment mechanism and pilot tax policies in commercial REITs needs attention [27].