(0) 财通证券 CAITONG SECURITIES 1、5月7日，证监会发布《推动公募基金高质量发展行动方案》，政策旨在鼓励基金确定合理的业绩比较基准、规范投资行为。《推动公募基金高质 量发展行动方案》提出：1）建立与基金业绩表现挂钩的浮动管理费收取机制，根据其持有期间产品业绩表现确定具体适用管理费率水平。2）强化业 绩比较基准的约束作用，明确基金产品业绩比较基准的设定、修改、披露、持续评估及纠偏机制。 2、相关政策背景在于近三年跑赢业绩基准的主动基金占比偏低。2015年至今，主动基金相对业绩基准的表现在不同市场环境下波动较大，其中 2016-2018年、2022-2024年间，跑赢基准的基金占比持续偏低，这与基金配置长期偏离基准不无联系。此次强化约束有利于纠偏基金业绩比较基准 设立不合理、基金风格漂移的现象，强化投资者信心。 3、当前以沪深300、中证800、中证500为业绩比较基准的基金规模，占全部生动基金的71%，普遍低配金融、公用。截至1Q25，以沪深300/中证 800/中证500为业绩比较基准的主动基金规模合计约2.5万亿元，三类基金分别占3.5万亿元主动基金的48%/19%/4%。其中：a） ...

作为衡量基金业绩的标尺，业绩比较基准有望发挥更重要的作用。 近日，证监会发布《推动公募基金高质量发展行动方案》（以下简称《行动方案》），提出强化业绩比 较基准的约束作用，明确基金业绩比较基准的设定、修改、披露、持续评估及纠偏机制，并对基金公司 选用基准的行为实施严格监管。 业内人士指出，此举旨在解决当前市场中存在的"风格漂移""赌赛道"等问题。业绩基准将成为更清晰的 标尺，帮助投资者精准识别基金的真实水平，推动公募基金迈向更高质量发展新阶段。 重塑行业生态 《行动方案》明确要求强化业绩比较基准的刚性约束，从设定、披露到纠偏全链条升级监管。 在新规约束下，基金产品业绩基准设定的逻辑以及基金经理的投资策略将面临深刻调整。 天相投顾基金评价中心表示，新规要求基金所选基准必须与产品类型和投资策略高度匹配，这一举措有 助于提高行业的透明度和一致性，确保基准能准确反映产品的投资方向和风险特征。 新规规定基金经理绩效薪酬需与三年以上的业绩表现挂钩，跑输基准将面临降薪压力，取得超额收益则 可能获得奖励，这将促使基金经理减少短期博弈行为，致力于获取长期稳定的超额收益。 以往部分基金"赌赛道"的做法也将受到制约。盈米基金研究院权 ...

Core Viewpoint - The China Securities Regulatory Commission (CSRC) aims to optimize the fee structure for actively managed equity funds, shifting from a fixed management fee model to a performance-based floating management fee model, thereby addressing the issue of fund companies benefiting regardless of performance [1][3]. Group 1: Fund Management Fee Structure - The current fixed management fee model incentivizes fund companies to increase fund size, as larger funds generate higher fees, leading to a phenomenon referred to as "guaranteed income" for fund companies [1][3]. - The CSRC emphasizes the need for fund companies to balance fund size and profitability, as larger fund sizes can dilute performance due to limited investment opportunities [3][6]. Group 2: Performance Metrics and Incentives - The introduction of performance benchmarks will serve as a standard for measuring fund performance, with funds required to report whether they outperform these benchmarks in their financial disclosures [5][6]. - The floating management fee model will link fees to fund performance, encouraging fund managers to achieve better returns for investors, as higher performance will result in higher fees [6]. Group 3: Long-term Investment Focus - The CSRC's action plan mandates a long-term assessment of fund performance, with at least 80% of the evaluation weight given to returns over a three-year period, promoting a culture of long-term investment among investors [6].

Core Viewpoint - The release of the "Action Plan for Promoting the High-Quality Development of Public Funds" has become a focal point in the industry, emphasizing the need to enhance the stability of fund investment behavior and address issues like "style drift" and "inconsistent products" [1][2] Group 1: Performance Benchmarking - The Action Plan strengthens the role of performance benchmarks as a "lifeline" for public fund products, establishing clear guidelines for setting, modifying, disclosing, and evaluating these benchmarks [2][3] - Fund companies are expected to be more cautious in setting performance benchmarks, potentially shifting the evaluation logic from beta returns to alpha returns [3][4] - The emphasis on performance benchmarks aims to constrain fund managers' investment behavior, ensuring they adhere to the agreed-upon industry or style, thereby reducing arbitrary deviations [2][3] Group 2: Theme Fund Regulation - The Action Plan proposes stricter registration and self-regulatory rules for theme funds, enhancing monitoring and analysis of fund investment transactions [4][5] - Historically, theme funds have been prone to style drift, with instances of funds misaligning their investments with their stated themes, which the new regulations aim to address [4][5] - The plan encourages clearer definitions of investment directions in fund names and contracts to prevent misleading practices [4][5] Group 3: Long-Term Assessment Mechanism - The Action Plan introduces a long-term assessment mechanism, mandating that at least 80% of the evaluation weight be based on performance over three years or more [5][6] - This mechanism is designed to reduce short-term market fluctuations' impact on investment performance evaluations, promoting a shift from a focus on scale to a focus on returns [6][7] - By encouraging a long-term investment approach, the plan aims to attract more stable capital into the stock market, enhancing market stability and resource allocation efficiency [6][7]

Core Viewpoint - The public fund industry in China is undergoing significant reforms aimed at addressing long-standing issues such as the disconnect between fund company profits and investor returns, with a focus on performance-based fee structures and manager compensation [1][2][3] Summary by Sections Industry Reform - The public fund industry has experienced rapid growth, with total assets exceeding 32 trillion yuan and over 12,600 products as of Q1 2023 [1] - Recent regulatory changes, including the "Action Plan for Promoting High-Quality Development of Public Funds," target key pain points in the industry, particularly fee structures and manager compensation [1][2] Fee Structure Changes - A new floating fee model linked to fund performance will be implemented for actively managed equity funds, moving away from the traditional fixed fee model [3][4] - This floating fee mechanism aims to align the interests of fund managers with those of investors, addressing the issue of "funds making money while investors do not" [3][4] - Historical examples show that some funds have already returned management fees when performance was below benchmarks, indicating a shift towards accountability [3] Manager Compensation Reform - Fund manager compensation will now be directly tied to fund performance, with at least 80% of performance evaluations based on investment returns [6][7] - A significant portion of funds has underperformed their benchmarks, with 23.25% of funds lagging by over 10 percentage points, indicating potential salary reductions for many managers [6][7] - The reform aims to create a more competitive environment where only capable managers and high-performing funds thrive [8] Performance Benchmarking - The establishment of clear performance benchmarks for each fund is a critical aspect of the reforms, intended to prevent "style drift" and ensure that investment actions align with fund names and objectives [9][10] - Over 60 funds have already adjusted their performance benchmarks this year to better reflect their investment strategies [10] - This focus on performance benchmarks is expected to enhance transparency and stability in risk-return profiles, improving investor confidence [11]

1. Report Industry Investment Rating No relevant content provided. 2. Core Viewpoints of the Report - On May 7th, the China Securities Regulatory Commission (CSRC) released the "Action Plan for Promoting the High - quality Development of Public Offering Funds", which is of milestone significance in the asset management industry. The plan proposes seven major aspects and 25 specific measures to promote the high - quality development of the public offering fund industry [2][7]. - The "Action Plan" has four major impacts on the public offering fund industry: different management fees among fund companies in the same echelon; exploration of performance comparison benchmarks and how to outperform them; emphasis on "investor profit and loss"; and focus on market opportunities for medium - low volatility products with equity and asset - allocation products [2]. - There are three paths that public offering funds need to focus on in the future: determining the appropriate tracking error for active equity funds, improving the investor profit - and - loss situation through a performance - based assessment system, and exploring investment strategies for medium - low volatility products with equity and asset - allocation products [2]. 3. Summary According to the Directory 3.1 The Four Major Impacts of the "Action Plan" on the Public Offering Fund Industry - **Management Fee Differences**: The "Action Plan" establishes a floating management fee collection mechanism linked to fund performance. In the future, there may be significant differences in management fees among fund companies in the same echelon, and second - echelon companies may charge higher fees than first - echelon ones [2][8]. - **Performance Comparison Benchmark**: The plan strengthens the binding effect of performance comparison benchmarks. The setting, modification, disclosure, and evaluation of benchmarks will be regulated. The concentration of benchmarks will enhance index Beta and reduce volatility. Attention to conventional SmartBeta indices will increase significantly. Active investment will become more passive, rule - based, and disciplined [2][9][10]. - **Investor Profit and Loss**: The "investor profit and loss situation" will be highly emphasized. Two directions are recommended: reducing product volatility and increasing the Sharpe ratio, and gradually shifting to an investment - advisory sales model [2][12]. - **Market Opportunities**: In addition to equity products, attention should be paid to market opportunities for medium - low volatility products with equity (such as fixed - income + funds) and asset - allocation products (such as FOF) [2][12]. 3.2 Three Paths that Public Offering Funds Need to Focus on in the Future 3.2.1 Appropriate Tracking Error for Active Equity Funds - Historical data on the proportion of active equity funds outperforming or underperforming the benchmark has little reference value due to the lack of emphasis on benchmarks in the past. The ratio of outperforming or underperforming is accidental and cannot predict the future [13][14]. - Enlarging the tracking error is a double - edged sword. Reducing the tracking error can improve the winning rate and safeguard the lower limit of excess returns. An 8% tracking error is an effective control indicator. When the tracking error is below 8%, the proportion of underperforming the benchmark by more than 10% decreases significantly [20]. 3.2.2 Improving Investor Profit and Loss through a Performance - Based Assessment System - **Low - Volatility Products**: Products with lower volatility result in lower investor return losses and stronger sense of gain [24]. - **High - Sharpe - Ratio Products**: Products with a high Sharpe ratio generally have stronger value - creation ability. Fund companies and investors can achieve a win - win situation by emphasizing the Sharpe ratio in product management [26]. - **Investment - Advisory Sales Model**: Fund managers and sales platforms should break the current hot - topic - chasing sales model and adopt an investment - advisory sales model [29]. 3.2.3 Investment Strategies for Medium - Low Volatility Products with Equity and Asset - Allocation Products - **Multi - level Fixed - Income + Strategy Matrix**: To address the structural differentiation in the demand side of the fixed - income + market, leading institutions are accelerating the construction of a multi - level fixed - income + strategy matrix, including asset - allocation, growth - oriented, dividend - based, quantitative, low - volatility, high - elasticity, stock - bond matching, multi - asset multi - strategy, small - cap stock strategy, and ETF - based fixed - income + strategies [32][33]. - **FOF Strategy Transformation**: FOF products are focusing on strategic transformation to release the effectiveness of asset allocation. Since 2024, the allocation ratio of QDII, commodities, and alternative assets in FOF has increased significantly. The TREE Long - Term Growth Plan, a one - stop asset - allocation solution jointly developed by China Merchants Bank's wealth management team and public offering fund management institutions, is widely recognized by the market. The FOF products included in the plan attracted a total of 19.515 billion yuan in the first quarter of 2025 [41][44][48].

Core Viewpoint - The "Action Plan for Promoting High-Quality Development of Public Funds" outlines policies aimed at reforming the public fund industry and enhancing its quality, focusing on optimizing fund operation models, improving industry assessment systems, increasing equity investment scale and proportion, and ensuring risk management [1][2]. Group 1: Fund Operation Model - The plan proposes establishing a floating fee rate mechanism linked to fund performance, enhancing the constraint of performance benchmarks, and creating a binding mechanism between fund company income and investor returns [1][2]. - The introduction of floating fee products is seen as a beneficial exploration of charging models, promoting a healthier industry development and aligning investor interests [2]. Group 2: Performance Benchmarking - The plan emphasizes strengthening the role of performance benchmarks by developing regulatory guidelines for their setting, modification, disclosure, and evaluation, which will guide industry institutions in selecting benchmarks rigorously [3]. - This will help ensure product style stability and assist investors in better evaluating fund performance [3]. Group 3: Industry Assessment and Investment Scale - The plan includes specific requirements for improving industry assessment systems, significantly increasing the scale and proportion of equity investments, and accelerating the establishment of top-tier investment institutions [4]. - Companies are encouraged to innovate and launch more floating fee products that are linked to fund performance and investor returns, promoting long-term holding [4]. Group 4: Compliance and Risk Management - Companies are expected to enhance compliance and risk management proactively, ensuring that all business operations run smoothly and securely [4]. - The focus will be on creating a virtuous cycle of "increased returns - inflow of funds - market stability" [3][4]. Group 5: Commitment to Investor Interests - Companies like E Fund are committed to prioritizing investor interests and promoting a financial culture that aligns with China's modernization goals, contributing to the stability of the capital market and high-quality economic development [5].

Core Viewpoint - The public fund industry in China is set to undergo significant fee rate reforms, introducing a floating management fee mechanism linked to fund performance, aiming to align the interests of fund managers and investors more closely [1][3]. Group 1: Floating Management Fee Mechanism - Over 20 large fund companies are expected to submit products based on performance benchmarks with a management fee structure comprising a basic fee, potential fees, and excess management fees [2][5]. - The new floating fee products will charge management fees based on the annualized return during the holding period compared to the benchmark, with differentiated fees for different investors based on their actual returns [2][4]. - This innovation emphasizes the anchoring role of performance benchmarks, incentivizing fund managers to pursue excess returns while penalizing them with reduced fees if performance falls short [2][3]. Group 2: Regulatory Emphasis on Investor Interests - The China Securities Regulatory Commission (CSRC) has highlighted the importance of binding fund company income to investor returns, aiming to eliminate the "guaranteed income" model for fund managers [3][4]. - The action plan mandates that new actively managed equity funds adopt a floating management fee model based on performance benchmarks, with specific fee rates determined by the fund's performance relative to the benchmark [3][4]. - The CSRC aims for leading fund institutions to issue at least 60% of their actively managed equity funds under this floating fee mechanism within the next year [3]. Group 3: Historical Context and Future Outlook - Previous fixed fee structures led to dissatisfaction among investors, prompting the introduction of floating fee products in late 2019, which allowed for performance-based fee extraction [5][6]. - Recent floating fee products have shown positive returns, with some exceeding 28% and others achieving over 40% returns, indicating a successful alignment of interests between fund managers and investors [6]. - The floating management fee model is expected to enhance the competitive edge of fund companies by focusing on research and investment capabilities, promoting long-term investment strategies among investors [6].

强化业绩比较基准约束作用 《行动方案》从优化基金运营模式、完善考核评价制度、大力发展权益类基金、守牢风险底线、强化监管执法、促进高质量发展等六方面提出了25条改革措 施，着力引导行业机构努力实现从"重规模"向"重投资者回报"转型，形成行业高质量发展的"拐点"，加快建设一流投资机构。 具体来看，《行动方案》全面建立以基金投资收益为核心的行业考核评价体系，将业绩比较基准对比、基金利润率等直接关乎投资者利益的指标引入考核体 系。 "强化业绩比较基准的约束作用在本次公募基金改革中发挥着较为关键的作用。"业内人士指出，这既关系到新的浮动管理费率产品的整体架构，也关系到基 金公司、高管及基金经理的绩效考核与薪酬激励。 通俗地说，业绩比较基准相当于基金投资的"锚"和"尺"，是基金公司根据产品类型、投资策略等因素选择的参考标准。其中"锚"的作用主要表现为明晰投资风 格、约束投资行为，防止基金产品在投资运作过程中，大幅偏离产品名称和定位；"尺"的作用主要表现为衡量基金是否跑赢市场，并据此对基金公司高管和 基金经理进行考核。从境外成熟市场经验看，业绩比较基准能够在很大程度上确保投资者对自己所投资的产品有一个客观的认识，并对这类产 ...

未来一年内，引导管理规模居前的行业头部机构，发行此类基金数量不低于其主动管理权益类基金发行 数量60%；试行一年后，及时开展评估，并予以优化完善，逐步全面推开。 同时，制定公募基金业绩比较基准监管指引，明确基金产品业绩比较基准的设定、修改、披露、持续评 估及纠偏机制，对基金公司选用业绩比较基准的行为实施严格监管，切实发挥其确定产品定位、明晰投 资策略、表征投资风格、衡量产品业绩、约束投资行为的作用。 《方案》明确，大力推行基于业绩比较基准的浮动管理费收取模式；督促基金公司建立健全与基金投资 收益相挂钩的薪酬管理机制。 5月7日，证监会印发《推动公募基金高质量发展行动方案》（下称《方案》），明确建立与基金业绩表 现挂钩的浮动管理费收取机制，强化业绩比较基准的约束作用。 具体来看，包括对新设立的主动管理权益类基金，将大力推行基于业绩比较基准的浮动管理费收取模 式；要求基金公司全面建立以基金投资收益为核心的考核体系，适当降低规模排名、收入利润等经营性 指标的考核权重；督促基金公司建立健全与基金投资收益相挂钩的薪酬管理机制等。 业内人士认为，强化业绩比较基准的约束作用，在此次公募基金改革中发挥着较为关键的作用，既关系 ...