Report Summary 1. Report Industry Investment Rating No industry investment rating is provided in the report. 2. Core Viewpoints On January 23, 2026, the China Securities Regulatory Commission issued the “Guidelines for Performance Comparison Benchmarks of Publicly - Offered Securities Investment Funds” (hereinafter referred to as the “Guidelines”), and the Asset Management Association of China released the “Operating Rules for Performance Comparison Benchmarks of Publicly - Offered Securities Investment Funds” (hereinafter referred to as the “Rules”). The implementation of the Guidelines starts on March 1, 2026, and a one - year implementation transition period is given for existing products with non - compliant performance comparison benchmark settings. The Guidelines aim to standardize the selection and use of performance comparison benchmarks for public funds, strengthen their role as an “anchor” for fund investment, and promote the high - quality development of the public fund industry [1][6]. 3. Summary by Directory Background The performance comparison benchmark is a reference standard set by fund managers for funds based on product positioning and investment objectives. It plays important roles such as determining product positioning, clarifying investment strategies, representing investment styles, measuring product performance, and restricting investment behaviors. Currently, there are problems in the performance comparison benchmarks of public funds, such as the lack of systematic regulatory systems, ineffective use and supervision by institutions, and “style drift” of funds. To address these issues, the China Securities Regulatory Commission issued the Guidelines to protect the legitimate rights and interests of investors [7]. Core Content - **Selecting Benchmark Specifications**: The selection of benchmarks should follow the principles of representativeness, objectivity, constraint, and persistence. The Asset Management Association of China is authorized to establish a benchmark element library, and fund managers can select benchmark elements from it [3][8]. - **Strict Benchmark Change Requirements**: Benchmarks should be persistent and cannot be changed casually. Specific situations and procedures for benchmark changes are clearly defined, and sales institutions are required to inform investors of benchmark changes in a timely manner [9][17]. - **Enhanced Benchmark Information Disclosure**: Information about benchmarks should be disclosed in fund legal documents and regular reports, and the fund trustee should strengthen the review and supervision of the disclosed content [9][10]. - **Strengthened Benchmark Constraint**: Fund managers should establish a full - process control mechanism for benchmarks, strengthen style stability management, and trustees should strengthen investment supervision responsibilities [10]. - **Highlighted Benchmark's Role in Measuring Performance**: Performance assessment, performance display, and fund evaluation should all be carried out in combination with the performance comparison benchmark, and different types of equity funds should not be directly ranked [11]. - **Transition Period Settings**: A one - year transition period is given for existing products with non - compliant benchmark settings. To ensure the objectivity and accuracy of related information, the relevant requirements are aligned with the one - year transition period. A six - month transition period is given for trustees to supervise the stability of fund investment styles [11]. Main Impacts - **Fund Managers**: They should establish an internal control and management system covering the entire process of benchmark selection, disclosure, monitoring, evaluation, correction, and accountability. Benchmark selection should follow four principles, and a department independent of the investment department should be established to monitor style stability. Information about benchmarks should be clearly stated in legal documents and regular reports, and the performance comparison benchmark should be displayed when showing past performance [12][14]. - **Fund Trustees**: They should carefully review the fund investment style library, establish a supervision mechanism for the stability of equity fund investment styles, and clarify rights and obligations with fund managers through agreements [14]. - **Fund Evaluation Institutions**: They should establish a fund evaluation system around the performance comparison benchmark, adjust the fund classification in a timely manner when the benchmark changes, and retain different stages of evaluation results [15]. - **Fund Sales Institutions**: When displaying a list of funds containing investment performance, they should distinguish funds of different investment styles based on the performance comparison benchmark and should not directly rank different types of equity funds [15].

Market Performance - On January 23, 2026, the A-share market saw all three major indices close higher, with the Shanghai Composite Index at 4136.16 points, up 0.33%, the Shenzhen Component Index at 14439.66 points, up 0.79%, and the ChiNext Index at 3349.50 points, up 0.63%. Over 3900 stocks rose, and the total trading volume in the Shanghai and Shenzhen markets was 3.09 trillion yuan, an increase of 390 billion yuan from the previous trading day [1] - The Hong Kong stock market opened higher and closed positively, with the Hang Seng Index rising 0.45% or 119.55 points to 26749.51 points, and a total trading volume of 240.87 billion HKD. The Hang Seng China Enterprises Index increased by 0.51% to 9160.81 points, while the Hang Seng Technology Index rose by 0.62% to 5798.01 points [1] Regulatory Developments - The China Securities Regulatory Commission (CSRC) is intensifying its crackdown on illegal fundraising, misappropriation, self-financing, and profit transfer in the private equity fund sector. In 2025, the CSRC organized 17,500 institutions for self-assessment and problem rectification, taking administrative measures against over 600 institutions and individuals, initiating about 30 investigations, and referring around 40 cases to public security [1] - In 2026, the CSRC will continue to urge private equity institutions to conduct self-examination and rectify various non-compliant behaviors [1] Fund Management Guidelines - On January 23, 2026, the CSRC released the "Guidelines for Performance Benchmarking of Publicly Raised Securities Investment Funds," effective from March 1, 2026. The guidelines emphasize the importance of performance benchmarks, requiring them to align with core elements of fund contracts and investment styles, and stipulating that once selected, they cannot be changed arbitrarily [2] - The guidelines also stress the need for enhanced internal controls and management by fund managers, requiring benchmarks to be determined by company management and establishing robust internal control mechanisms [2] - External constraints on performance benchmarks will be strengthened, with clear supervisory responsibilities for fund custodians and regulations for fund sales and evaluation institutions regarding the display and use of benchmarks [2] - The CSRC will enforce strict supervision of fund managers, custodians, sales institutions, evaluation institutions, and their personnel for any violations [2]

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has developed the "Guidelines for the Performance Benchmark of Publicly Offered Securities Investment Funds" to enhance the quality of public fund management and protect investors' rights, effective from March 1, 2026 [1][3]. Group 1: Issues in Current Fund Performance Benchmarking - The current public fund performance benchmarks lack specialized and systematic regulations, with only scattered requirements in information disclosure and special product design [2]. - Many fund managers have not established comprehensive internal control mechanisms covering performance benchmarks, and custodians and sales institutions have not effectively supervised or utilized these benchmarks [2]. - Some actively managed equity funds have significantly deviated from their performance benchmarks, with certain products experiencing "style drift," negatively impacting investor perception [2]. Group 2: Key Features of the Guidelines - The guidelines emphasize the representational role of performance benchmarks, stating that they must align with the core elements of the fund contract and the product's investment style, and should not be changed arbitrarily once selected [3]. - Fund managers are required to strengthen internal controls and management, with performance benchmarks determined by company management and a robust internal control mechanism established [3]. - The guidelines enhance external constraints on performance benchmarks, clarifying the supervisory responsibilities of fund custodians and regulating the behavior of fund sales and evaluation institutions [3]. Group 3: Regulatory Enforcement - The CSRC and its local agencies will enforce regulations against illegal activities by fund managers, custodians, sales institutions, evaluation agencies, and their personnel [3][4].

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has established the "Guidelines for Performance Benchmark of Publicly Raised Securities Investment Funds" to enhance the quality of public fund development, emphasizing investor protection and the proper use of performance benchmarks [2][3]. Summary by Sections Section 1: Importance of Performance Benchmarks - The guidelines highlight the significance of performance benchmarks in representing product investment styles and measuring performance, stressing that once selected, these benchmarks should not be changed arbitrarily [3]. Section 2: Internal Control and Management - Fund management companies are required to have their management teams decide on performance benchmarks, and they must establish robust internal control mechanisms to ensure the stability of fund managers and investment styles [3]. Section 3: External Constraints on Performance Benchmarks - The guidelines specify the supervisory responsibilities of fund custodians and regulate the behavior of fund sales institutions and evaluation agencies regarding the use of performance benchmarks, emphasizing the need for investor education [3]. Section 4: Regulatory Oversight - The CSRC and its local agencies will enforce laws against violations by fund managers, custodians, sales institutions, evaluation agencies, and their personnel [3]. Section 5: Public Feedback and Implementation - Prior to finalizing the guidelines, the CSRC sought public opinions, which were generally supportive, leading to modifications based on the feedback received. The CSRC will oversee the implementation of these guidelines [3].

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has issued guidelines for the performance comparison benchmarks of publicly offered securities investment funds, effective from March 1, 2026, emphasizing the importance of stable and serious application of these benchmarks [1] Group 1: Performance Comparison Benchmarks - The guidelines highlight the representational role of performance comparison benchmarks, stressing that they must align with the core elements of the fund contract and the investment style of the product, and cannot be changed arbitrarily once selected [1] - The guidelines reinforce the internal control and management responsibilities of fund managers, stating that the benchmarks should be determined by the management team, and that a robust internal control mechanism and management system must be established [1] Group 2: External Constraints and Supervision - The guidelines enhance external constraints on performance comparison benchmarks, clarifying the supervisory responsibilities of fund custodians and regulating the behavior of fund sales institutions and evaluation agencies regarding the display and application of these benchmarks [1] - The CSRC and its local agencies will strictly regulate and address any illegal activities by fund managers, custodians, sales institutions, evaluation agencies, and their personnel [1]

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has publicly solicited opinions on the "Guidelines for Performance Benchmarking of Publicly Raised Securities Investment Funds (Draft for Comments)" which aims to enhance the regulation and standardization of performance benchmarks in the fund industry [1] Group 1: Key Content of the Guidelines - The guidelines consist of six chapters and 21 articles, emphasizing the representational role of performance benchmarks, which should reflect the core elements and investment style agreed upon in the fund contract and should not be changed arbitrarily once selected [1] - The guidelines strengthen the binding role of performance benchmarks, requiring fund managers to establish a comprehensive internal control mechanism to enhance decision-making levels and ensure the stability of investment styles [1] - The guidelines aim to standardize the evaluation role of performance benchmarks, regulating their use in salary assessments, fund sales, and fund evaluations [1] - The guidelines propose a multi-layered defense mechanism, enhancing information disclosure and supervision by fund custodians, in addition to self-regulation by fund managers [1] Group 2: Supporting Documents - The Asset Management Association of China is concurrently drafting the "Operational Guidelines for Performance Benchmarking of Publicly Raised Securities Investment Funds (Draft for Comments)" to provide further clarity on the selection, display, information disclosure, risk control, and compliance management of performance benchmarks [1]

Core Points - The China Securities Investment Fund Industry Association has drafted the "Operational Guidelines for Performance Benchmark Selection and Use of Publicly Raised Securities Investment Funds (Draft for Comments)" to enhance the quality of public funds and protect investors' rights [2][3] - The guidelines aim to standardize the selection and use of performance benchmarks, improve internal controls of fund managers, and ensure compliance with relevant laws and regulations [2] Summary by Sections Performance Benchmark Representation - The performance benchmark should reflect the core elements and investment style stipulated in the fund contract and should not be changed arbitrarily once selected [2] Internal Control Mechanism - Fund managers are required to establish a comprehensive internal control mechanism to enhance decision-making processes and ensure the stability of investment styles [3] Evaluation and Accountability - The guidelines emphasize the role of performance benchmarks in evaluating fund performance, which includes requirements for salary assessments, fund sales, and fund evaluations [3] Information Disclosure and Supervision - There is a focus on strengthening information disclosure and supervision by fund custodians, building multiple layers of defense beyond self-regulation by fund managers [3]

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has drafted the "Guidelines for Performance Comparison Benchmarks of Publicly Raised Securities Investment Funds (Draft for Comments)" and is seeking public feedback, aiming to standardize fund managers' investment behavior and enhance investor experience [1][2]. Summary by Sections General Principles - The guidelines consist of 21 articles divided into six chapters, emphasizing the representativeness and objectivity of performance comparison benchmarks [1]. Constraints on Performance Benchmarks - The new regulations state that performance benchmarks cannot be adjusted arbitrarily due to short-term factors, and any changes must follow specific procedures, including announcements and informing investors [2]. Evaluation Role of Performance Benchmarks - The guidelines also standardize the use of performance benchmarks in salary assessments, fund sales, and fund evaluations [2]. Strengthening Supervision - There is a focus on enhancing information disclosure and supervision by fund custodians, establishing multiple layers of defense beyond self-regulation by fund managers [3].

Core Viewpoint - The China Securities Investment Fund Industry Association has drafted the "Operational Guidelines for the Selection and Use of Performance Benchmarks for Publicly Raised Securities Investment Funds (Draft for Comments)" to standardize the selection and use of performance benchmarks, enhance internal controls of fund managers, and protect investors' rights [1][3]. Group 1: Regulatory Framework - The guidelines are based on various laws and regulations, including the Securities Investment Fund Law and the Management Measures for Publicly Raised Securities Investment Funds [3][4]. - The guidelines apply to fund managers, custodians, and evaluation institutions involved in the selection and use of performance benchmarks [4]. Group 2: Requirements for Fund Managers - Fund managers are required to establish a comprehensive mechanism covering the selection, disclosure, monitoring, evaluation, and accountability of performance benchmarks [4][10]. - The performance benchmark should reflect the fund's investment objectives, scope, strategy, and style [10][11]. Group 3: Benchmark Selection and Matching - Performance benchmarks must match the main asset types that the fund can invest in, with specific guidelines for equity and bond funds [6][7]. - For equity funds, benchmarks should generally be broad-based indices or specific strategy indices, while bond funds should use mainstream comprehensive bond indices [6][9]. Group 4: Disclosure and Reporting - Fund managers must disclose the fund's actual investment performance compared to the benchmark in regular reports, covering various time frames [8][9]. - Any changes to the performance benchmark must be reported within one year, detailing the differences and reasons for the change [9]. Group 5: Internal Control and Compliance - Fund managers must implement a management mechanism for performance benchmarks that includes risk control and compliance checks [10][11]. - Compliance departments are responsible for reviewing the legality and compliance of benchmark selection and usage [11]. Group 6: External Supervision - Fund custodians are tasked with establishing mechanisms for reviewing contracts, monitoring investments, and verifying disclosures related to performance benchmarks [12][13]. - Custodians must ensure that the selected benchmarks are representative and objective, and they should communicate any discrepancies to fund managers [12][13]. Group 7: Self-Regulation and Violations - The association will take self-regulatory measures or disciplinary actions based on the nature and circumstances of any violations by fund managers or custodians [15][16]. - Violations of laws or regulations will be reported to the China Securities Regulatory Commission for further action [15].

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has drafted the "Guidelines for the Performance Benchmark of Publicly Offered Securities Investment Funds (Draft for Comments)" to standardize the selection and use of performance benchmarks in the mutual fund industry, aiming to enhance internal controls and protect investors' rights [2][3]. Group 1: Guidelines Overview - The guidelines consist of six chapters and twenty-one articles, emphasizing the representation function of performance benchmarks, which should reflect the core elements and investment style agreed upon in the fund contract and should not be changed arbitrarily once selected [2]. - The guidelines strengthen the constraint function of performance benchmarks, requiring fund managers to establish a comprehensive internal control mechanism to ensure the stability of investment styles [2]. - The guidelines aim to standardize the use of performance benchmarks in salary assessments, fund sales, and fund evaluations, thereby enhancing their evaluative function [2]. - The guidelines propose a multi-layered defense system, enhancing information disclosure and supervision by fund custodians, in addition to self-restraint by fund managers [2]. Group 2: Industry Association's Role - The Asset Management Association of China has concurrently drafted the "Operational Details for the Performance Benchmark of Publicly Offered Securities Investment Funds (Draft for Comments)" to provide specific operational norms regarding the selection, disclosure, risk control, and compliance management of performance benchmarks [3]. - The CSRC invites public feedback on the guidelines, indicating that revisions will be made based on the comments received before final implementation [3].