证券研究报告：固定收益报告 发布时间：2025-11-21 研究所 分析师:梁伟超 SAC 登记编号:S1340523070001 Email:liangweichao@cnpsec.com 研究助理:谢鹏 SAC 登记编号:S1340124010004 Email:xiepeng@cnpsec.com 近期研究报告 《生产热度持续回落，原油铜价小幅回 升——高频数据跟踪 20251116》 - 2025.11.17 固收专题 从资管信托新规，看银行理财变局 ——机构行为专题二 20251120 近期金融监管总局公布《资产管理信托管理办法（征求意见稿）》 （以下简称"资管信托新规"）明确理财投资信托集中度限制，引发市 场热议。理财信托合作现状如何？如何看待资管信托新规及其影响， 本文对此进行详细分析。 ⚫ 历史现状梳理：理财持有信托的规模和机制 理财委外持续增长，占比已超一半。资管新规实施以来，理财子 明显加大委外投资力度，2025 年二季度末穿透前理财委外占比首次超 过 50%。 信托三大优势明显，成为理财最主要合作机构之一。从理财前十 大持仓来看，信托持仓逐年快速攀升，截至 2025 年三季度末，前十 大 ...

Core Viewpoint - The introduction of the new regulatory framework for asset management trusts marks a significant shift in the trust industry, emphasizing a transition from a financing intermediary to a true asset management institution, enhancing compliance and operational standards [1][11][12]. Group 1: Regulatory Framework - The National Financial Regulatory Administration has released a draft for the "Asset Management Trust Management Measures," which is open for public feedback until December 1, 2025 [1]. - The new measures require trust companies to strengthen comprehensive management and clearly define regulations for key business areas such as channel services, fund pools, and related transactions [5][6]. - The measures establish three key "red lines" for asset management trusts: adherence to the essence of asset management, maintaining a private placement position, and setting a minimum net asset requirement of 3 million yuan for investors [1][10]. Group 2: Operational Management - The draft consists of five chapters and eighty-five articles, detailing the establishment, modification, and termination of asset management trust products, as well as standards for qualified investors and risk assessment [5]. - Trust companies are mandated to enhance the management of asset management trust products throughout their lifecycle, including strict regulations on product establishment, sales, and risk management [5][8]. - The measures prohibit trust companies from promising investors against capital loss or minimum returns, and from engaging in certain high-risk financing activities [7][10]. Group 3: Investor Standards - Asset management trusts are defined as private asset management products based on trust law, with strict investor qualifications and a cap of 200 investors per product [9][10]. - Qualified individual investors must meet specific criteria, such as having a family financial net worth of at least 3 million yuan or an average annual income of 400,000 yuan over the past three years [10]. - The tightening of investor standards is seen as a crucial step in transforming the trust industry, focusing on high-net-worth clients and reducing disputes [10][11]. Group 4: Industry Impact - The new measures are expected to accelerate the elimination of weaker players in the industry, pushing trust companies to invest in research, risk control, and financial technology to build core competitiveness [8][11]. - The regulatory changes are anticipated to lead to a significant transformation in the trust industry, moving from traditional financing roles to investment and service-oriented functions [11][12]. - The overall trust asset management scale is projected to exceed 30 trillion yuan, with asset management trusts becoming a dominant force in driving industry growth [13].