11月11日，根据中国证券监督管理委员会浙江监管局发布的行政处罚决定书，实质上实施私募基金从业 者履职行为的林艺平，因利用未公开信息交易股票而受到重罚。 经查明，林艺平存在以下违法事实： 三、林艺平控制、使用案涉账户组趋同交易情况 2022年11月16日至2023年9月6日期间，林艺平控制使用"林某治"国金、东莞证券账户及"何某龙"东莞、 中信证券账户，在沪深两市趋同买入股票并盈利。 浙江证监局认为，林艺平的前述行为违反《私募投资基金监督管理暂行办法》《私募投资基金监督管理 条例》（以下简称《私募条例》）规定，构成利用未公开信息交易股票的违法行为。 根据林艺平违法行为的事实、性质、情节与社会危害程度，依据《基金法》《私募条例》的规定，浙江 证监局决定：对林艺平责令改正，给予警告，没收违法所得8857.69万元，并处以8857.69万元罚款，合 计罚没1.77亿元。因当事人林艺平的违法行为情节严重，依据相关法律法规的规定，该局决定对林艺平 采取5年证券市场禁入措施。林艺平应在收到处罚决定书之日起15日内将罚没款汇交国库，并可在60日 内申请行政复议或在6个月内提起行政诉讼。 二、林艺平控制、使用"林某治""何某 ...

Core Viewpoint - The article emphasizes the significance of small to medium-sized private fund managers in the industry, highlighting the innovative strategies and risk management systems of Shanghai Sidaxinghui Private Fund Management Co., Ltd. [3] Company Overview - Shanghai Sidaxinghui Private Fund Management Co., Ltd. is a securities private fund company supported by the Shanghai State-owned Assets Supervision and Administration Commission and the China Chief Economist Forum [4] - The company is led by a team of experienced professionals, including Dr. Pang Yang, who has a PhD in Physics from Columbia University and extensive experience in quantitative modeling, and Ms. Cao Qingqing, who has a PhD in Computer Science from Shanghai Jiao Tong University [4][9] - The firm focuses on a classic all-weather strategy and has developed a unique Quantimental fundamental quantitative enhancement system [4] Core Team - The core team is composed of graduates from prestigious universities and aims to achieve long-term absolute return investment value for investors [9] Strategy Overview - The investment philosophy of Sidaxinghui is centered on "crossing cycles, steady and far-reaching," utilizing a quantitative all-weather enhancement strategy [13] - The firm emphasizes a deep understanding of cycles and systematic risk management in its investment approach [13] Core Strategies and Representative Products - The quantitative all-weather enhancement system has been refined since its launch in early 2019, achieving significant returns across different economic phases [17] - The company has launched a series of products, including "Tianji No. 1," which has shown impressive cumulative returns while maintaining strict risk controls [17] - The firm also offers auxiliary strategies that reflect its absolute return philosophy and showcase its multi-dimensional investment capabilities [18] Investment Framework - The investment framework combines Beta and Alpha, with Beta contributing approximately 70% and Alpha about 30% to the risk-return profile [22][23] Advantages - The team possesses a global perspective and local insights, combining international macro allocation with practical experience in the Chinese market [30] - The all-weather enhancement strategy integrates macro, fundamental, volume, and risk factors, achieving a dual-driven structure of risk parity and excess returns [31] - The firm has established a robust compliance and operational system backed by state-owned shareholders and leading custodians [33] - A long-termism and compounding culture is emphasized, focusing on providing investors with a stable investment experience [34] Continuous Evolution Capability - Sidaxinghui recognizes that long-term competitiveness comes from a systematic ability to evolve and adapt to market changes [35] - The company has implemented a data-driven closed-loop system for research, strategy, risk control, and execution [37] - Future plans include expanding global multi-asset layouts and exploring AI-driven asset pricing models [39]

Core Viewpoint - The recent revisions to the Private Investment Fund Registration Guidelines No. 3 by the Asset Management Association of China, in collaboration with the Beijing Financial Court, signify a new phase in the risk management of private funds, emphasizing a combination of self-regulation and judicial practice [1][6]. Summary by Relevant Sections Regulatory Changes - The revised guidelines optimize the management change process and respect contractual autonomy, providing a clear institutional path to address issues of "lost" or "ineffective" fund managers [1][2]. - The new guidelines reduce the number of articles from 19 to 16, reflecting a streamlined approach to managing fund changes [2]. - Key revisions include respecting contractual agreements, simplifying decision-making documents, clarifying procedural bases, focusing on management changes, and expanding the applicability of management changes [2][3]. Judicial Support - The Asset Management Association of China and the Beijing Financial Court released two typical cases that provide judicial examples for addressing the challenges posed by ineffective fund managers [4][5]. - These cases illustrate how courts can facilitate the resolution of fund management issues and protect investor rights through flexible legal measures [4][5]. Industry Implications - The new guidelines and judicial cases are expected to enhance the operational efficiency of changing fund managers, thereby addressing existing risks and safeguarding investor interests [3][6]. - The collaborative approach between regulatory and judicial bodies marks a significant step towards a more transparent and sustainable development of the private fund market [6][7]. Future Directions - The Asset Management Association of China plans to continue strengthening financial legal cooperation under the guidance of the China Securities Regulatory Commission, aiming to create a more regulated and vibrant industry ecosystem [7].

具体来说，主要修订内容包含五个方面：一是尊重合同约定，增加"生前遗嘱"条款；二是简化决议文 件，优化投资者决议变更管理人程序；三是明确办理依据，畅通司法仲裁与自律衔接；四是聚焦管理人 变更，删除成立清算组相关条款；五是响应投资者诉求，扩大管理人变更适用范围。 君合律师事务所王曼表示，本次修订在调研行业意见、总结司法实践基础上，对原有规则进行了系统优 化，旨在提升制度的适用性与操作性，推动形成"以契约自治为基础、以自律监管为保障"的风险处置机 制。新版指引通过优化表决机制、简化程序要求、畅通司法衔接、扩大适用范围等关键环节的系统改 进，显著提升了私募基金变更管理人的操作性与效率，为化解存量风险、维护投资者权益提供了制度保 障。 近日，中国证券投资基金业协会发布修订后的《私募投资基金备案指引第3号——私募投资基金变更管 理人》，并与北京金融法院联合推出两则典型案例，标志着私募基金风险处置步入"自律规范+司法实 践"协同发力新阶段。 新规通过优化变更程序、尊重契约自治等五大方面修订，为化解管理人"失联""失能"困境提供了清晰的 制度路径；而配套案例则从代表诉讼与强制执行等司法层面，为破解清算僵局提供了关键实操范例。 ...

Core Insights - The private equity industry has seen a significant increase in the number of private equity firms managing over 10 billion yuan, rising from 96 to 113 in just one month, with a net increase of 17 firms [1][2] - The growth is driven by three main factors: concentration of resources towards leading firms, strong performance in the stock market boosting investor sentiment, and overall impressive returns from private equity funds, particularly quantitative strategies [1][2] Group 1: Industry Growth - As of October 31, 2025, the total number of private equity firms managing over 10 billion yuan has reached 113, with 18 new firms joining the ranks [1] - Among the new entrants, 10 are first-time firms surpassing the 10 billion yuan threshold, including notable quantitative and subjective private equity firms [1] - The industry has also seen a return of 8 firms that had previously exited the "10 billion yuan club" [1] Group 2: Investment Strategies - Quantitative private equity firms have emerged as the dominant force in this expansion, with 10 out of the 18 new firms employing quantitative strategies [2] - As of the end of October, quantitative firms make up 48.67% of the 113 firms, while subjective firms account for 41.59% and mixed strategy firms represent 7.96% [2] - The average return for the 74 firms with performance data is 29.57%, with quantitative firms achieving an average return of 32.88%, outperforming subjective and mixed strategy firms [2][3] Group 3: Performance Metrics - Among the 38 firms with average returns exceeding 30%, 28 are quantitative firms, indicating a strong performance concentration in this strategy [3] - Four quantitative firms have reported average returns over 50%, showcasing exceptional performance in the sector [3] - The future of the private equity industry is expected to be diversified, with quantitative firms likely to continue their strong growth, while subjective firms provide valuable insights through in-depth research [3]

Core Viewpoint - The revised guidelines for private equity fund management aim to address issues related to "missing" or "incapacitated" fund managers, facilitating smoother transitions and protecting investors' rights [3][4]. Group 1: Regulatory Changes - The China Securities Investment Fund Industry Association has released a revised version of the "Private Investment Fund Filing Guidelines No. 3," which clarifies the standard procedures and documentation required for changing fund managers [3][4]. - The revision compresses the original 19 articles into 16, reflecting the need for adaptation to current industry realities and judicial practices [3][4]. Group 2: Key Amendments - The revised guidelines include five main changes: 1. Respect for contractual agreements with the addition of a "living will" clause 2. Simplification of resolution documents to optimize the process for investors to change fund managers 3. Clarification of the basis for processing, enhancing the connection between judicial arbitration and self-regulation 4. Focus on manager changes by removing clauses related to the establishment of liquidation groups 5. Expansion of the applicability of manager changes in response to investor demands [4][5]. Group 3: Judicial Support - The association, in collaboration with the Beijing Financial Court, has published two typical cases addressing the issue of incapacitated fund managers, providing judicial examples for fund risk resolution [5][6]. - These cases illustrate how investor meetings can authorize representatives to handle fund liquidation and legal claims, thereby confirming the legitimacy of such actions in court [5][6]. Group 4: Future Directions - The new guidelines and judicial cases reflect a coordinated effort between financial regulation and judicial enforcement, aiming to enhance the quality and transparency of the private equity fund industry [7]. - The association plans to continue strengthening financial legal cooperation under the guidance of the China Securities Regulatory Commission, promoting deeper governance within the private equity sector [7].

Core Viewpoint - The A-share market in October experienced high-level fluctuations, with the Shanghai Composite Index showing relative strength, while the Shenzhen Component Index and the ChiNext Index faced pressure. The performance of large-scale private equity funds, particularly those with over 10 billion yuan in assets, stood out in this environment, demonstrating strong research and risk control capabilities [2][3]. Market Performance - In October, the Shanghai Composite Index rose by 1.85%, while the Shenzhen Component Index and ChiNext Index fell by 1.10% and 1.56%, respectively [2]. - The average return of 5,189 private equity products with performance data was 29.04% from January to October, with a mere 0.03% return in October. In contrast, the 662 products under large private equity funds achieved an average return of 1.10% in October and 30.38% year-to-date [2][3]. Private Equity Fund Performance - The performance of private equity funds categorized by size showed that funds with over 10 billion yuan had the highest returns, with an average of 30.38% from January to October [3]. - The average returns for different fund sizes in October were as follows: - 0-5 billion yuan: -0.11% - 5-10 billion yuan: -0.22% - 10-20 billion yuan: -0.12% - 20-50 billion yuan: 0.04% - 50-100 billion yuan: -0.32% - 100 billion yuan and above: 1.10% [3]. Strategy Performance - Among the strategies, stock strategies and multi-asset strategies performed best, with average returns of 33.65% and 23.17%, respectively, from January to October. The quantitative long strategy had the highest average return at 44.65% [3][4]. - The average returns for various strategies in October were: - Multi-asset strategies: 1.67% - Stock strategies: 1.12% - Quantitative long strategies: 1.10% [4][10]. Top Performing Products - The top-performing products in the stock strategy category achieved an average return of 33.65% year-to-date, with the top three products managed by Yuanxin Investment, Jiuku Investment, and Yinye Investment [5]. - In the quantitative long strategy, the top three products were from Longqi Technology, Evolutionary Theory Asset, and Stable Investment, with an average return of 44.65% year-to-date [10][12]. Notable Fund Managers - Wang Aoye from Yuanxin Investment, with a strong background in media and technology, managed a product that achieved significant returns despite market challenges [8]. - Zhu Xiaokang from Longqi Technology, with extensive experience in quantitative strategies, led a product that ranked first in excess returns [13].

Core Insights - The Shanghai Composite Index has notably surpassed the 4000-point mark for the first time in ten years, indicating a significant market rebound and attracting increased investment from private equity funds [1] - Private equity firms have shown strong confidence in the long-term value of A-shares and economic recovery, leading to higher allocation levels and a record high in private equity positions [1] - As of October 31, 2025, the stock private equity position index reached 80.16%, marking a 0.79% increase from the previous week and the first time it has crossed the 80% threshold this year [1] Private Equity Performance - The performance of private equity products has been outstanding this year, with an average return of 29.57% for 74 billion-yuan private equity firms as of October 31, 2025 [2] - A significant 97.30% of these firms reported positive returns, indicating strong investment capabilities and market adaptability [2] - Quantitative private equity firms have outperformed subjective firms, with average returns of 32.88% compared to 25.12% for subjective firms, highlighting the advantages of quantitative strategies [2][3] Growth in Private Equity Firms - The number of billion-yuan private equity firms surged to 113 by October 31, 2025, an increase of 17 firms from the previous month, showcasing the industry's vitality [4] - The growth is attributed to the concentration of resources among leading firms, which attract more capital due to their research capabilities and risk management systems [4] - Among the new entrants, 10 are quantitative private equity firms, emphasizing the dominance of quantitative strategies in the current market [4][6] Market Dynamics - As of October 31, 2025, quantitative private equity firms accounted for 55 out of 113 billion-yuan firms, representing 48.67% of the total, while subjective firms made up 41.59% [6] - The future of the private equity industry is expected to be diversified, with different investment models coexisting and complementing each other [6] - Quantitative firms are likely to maintain strong growth due to their market adaptability, while subjective firms will continue to provide value through in-depth research and macro trend analysis [6]

Core Insights - Infrastructure private credit serves as a crucial financial bridge connecting long-term capital with long-term assets, providing investors with a defensive, stable return, and inflation-resistant alternative asset class while offering flexible financing for essential infrastructure projects [1][6][7] Infrastructure Private Credit Industry Definition and Advantages - Private credit funds, also known as private debt financing, primarily cater to the urgent financing needs of private enterprises, including corporate loans, real estate financing, asset-backed financing, and infrastructure loans [1][4] - Infrastructure loans are categorized into economic and social infrastructure loans, providing long-term debt financing for the construction, expansion, or maintenance of infrastructure projects [1][4] - Infrastructure private credit offers superior risk-return characteristics, stable long-term cash flows, and includes a liquidity premium, yielding significantly higher returns compared to high-yield bonds and leveraged loans [3][4] Current Development Status of the Infrastructure Private Credit Industry - The global infrastructure investment gap is projected to reach $3 trillion in 2024, with a total gap of $4 trillion from 2016 to 2024, creating favorable conditions for the growth of infrastructure private credit [4][5] - Total global infrastructure spending from 2025 to 2040 is expected to reach approximately $54.4 trillion, while actual investment needs are estimated at $65.3 trillion, resulting in a projected investment gap of $10.9 trillion [4][5] Industry Chain of Infrastructure Private Credit - The industry chain consists of "capital supply → professional management → asset allocation → value realization," with upstream investors including pension funds, insurance capital, sovereign wealth funds, and high-net-worth individuals [7][8] - The midstream involves infrastructure private credit fund management, while the downstream consists of borrowers in sectors such as energy, transportation, communication, and social infrastructure [7][8] Competitive Landscape of the Infrastructure Private Credit Industry - The private fund market has seen increased competition, with a growing concentration of market players, as private funds attract high-net-worth individuals and institutional investors [8][9] - Infrastructure projects are a significant investment direction for private funds, particularly in public facilities like transportation and energy [8][9] Development Trends in the Infrastructure Private Credit Industry - Trends such as digitalization, de-globalization, and decarbonization are expected to drive demand for infrastructure private credit investments, with trillions of dollars needed for renewable energy and green infrastructure [9][10] - Structural innovations are expanding the global reach and investor base of infrastructure private credit, with listed funds providing attractive options for investors seeking stability, yield, and risk exposure [10]

每经编辑｜许绍航 肖芮冬 存在盘中拉抬打压股价等违规行为 被出具警示函 近日，浙江浩坤昇发资产管理有限公司（以下简称浙江浩坤昇发资产）被浙江证监局出具警示函。据了解，该公司存在不公平对待公司管理的不同基金财 产、私募基金宣传推介材料有误导性陈述、同日反向交易无决策依据留存记录等多项违规行为。 此外，公司法定代表人及总经理张门发，时任实际经营管理人员、基金经理葛仲夫也被采取出具警示函的监督管理措施。值得一提的是，张门发曾在2015 年5月至2017年7月担任财经评论员。 记者注意到，浙江浩坤昇发资产旗下多只产品在今年三季度扎堆北交所大牛股，涉及个股包括佳合科技、恒合股份、宏裕包材、美之高、锦好医疗等。 中国证券投资基金业协会数据显示，截至目前，浙江浩坤昇发资产管理规模为20亿~50亿元，公司实控人为张门发，持有公司股份51%。从履历来看，张 门发2010年10月至2015年4月在中国人民大学经济学院担任培训讲师，2015年5月至2017年7月担任财经评论员，2017年8月至今在浙江浩坤昇发资产担任总 经理等职。 根据监管披露信息，经查，浙江浩坤昇发资产不公平对待公司管理的不同基金财产、私募基金宣传推介材料有误导 ...