Investment Rating - The report provides a positive outlook on the non-banking financial sector, indicating a strong performance and potential for continued growth in the coming years [1][2]. Core Insights - The report highlights the introduction of multiple regulatory frameworks aimed at strengthening the long-term performance of the non-banking sector, which is expected to enhance the overall stability and growth prospects of the industry [1][39]. - The insurance market is expanding steadily, with significant growth in premium income and investment returns, indicating a robust recovery and potential for further development [7][58]. - The report emphasizes the performance of various non-banking sectors, with insurance leading the growth, followed by diversified finance and securities [22][58]. Summary by Sections Regulatory Dynamics - The China Banking and Insurance Regulatory Commission (CBIRC) has introduced several new regulations, including adjustments to risk factors for insurance companies and management guidelines for financial leasing companies, aimed at enhancing regulatory efficiency and promoting high-quality development in the non-banking sector [3][39]. - New regulations also include the asset-liability management guidelines for insurance companies and the information disclosure management for asset management products, which are expected to improve transparency and investor protection [40][43]. Industry Dynamics - The non-banking sector has shown varied performance, with the insurance sector achieving a premium income of CNY 5.76 trillion, a year-on-year increase of 7.56% [58]. - The report notes that the A-share market's average daily trading volume reached CNY 10,768 billion, reflecting a year-on-year growth of 53.24%, although there was a slight decline in trading activity towards the end of the year [10][64]. Market Performance - In December 2025, the non-banking index rose by 6.31%, outperforming major indices, with insurance stocks showing the highest gains at 14.59% [19][22]. - The report identifies key ETFs in the non-banking sector, highlighting strong performance in the securities insurance ETFs and financial technology ETFs, which saw significant inflows [13][38]. Investment Opportunities - The report recommends focusing on the valuation recovery logic in the non-banking sector, particularly in ETFs such as the Hong Kong Stock Connect Non-Banking ETF and the Financial Technology ETF, which are expected to benefit from the positive market dynamics [13][38]. - The insurance sector's dividend yields are becoming increasingly attractive, with several companies offering yields above 3.5%, indicating a potential investment opportunity for income-focused investors [12].

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has announced the pilot program for commercial real estate investment trusts (REITs), aiming to enhance the functionality of REITs in revitalizing existing assets, increasing direct financing, and meeting residents' wealth management needs [1] Group 1: Market Development and Performance - The REITs market in China has steadily developed over five years, with 78 REITs listed as of December 27, 2025, raising a total of 209.9 billion yuan and achieving a total market value of 219.9 billion yuan [1] - The CSI REITs total return index has increased by 19% since 2024, indicating that REITs are becoming an important asset class for investment [1] Group 2: Announcement Details - The announcement defines commercial real estate REITs as closed-end publicly raised securities investment funds that hold commercial real estate to generate stable cash flows and distribute profits to fund shareholders [2] - It outlines requirements for fund registration and operational management, including responsibilities for fund managers and custodians, due diligence, and application materials [2] - The announcement emphasizes the importance of strict compliance with professional standards and regulatory requirements by fund managers and professional institutions [2] Group 3: Support for Development - The CSRC's notification supports the stable and healthy development of commercial real estate REITs, focusing on assets that align with policy directions and possess commercial attributes [3] - It encourages the integration of assets with similar operations and functions to enhance scale effects and risk diversification [3] - The notification supports financial institutions with robust asset management experience, such as banks and insurance companies, to participate in commercial real estate REITs [3] Group 4: Market Expansion and Innovation - The notification aims to expand the REITs market by increasing the supply of quality REITs and promoting a diverse and orderly growth of market segments [4] - It supports listed REITs with strong governance and high-quality information disclosure to enhance their asset scale and risk resilience through acquisitions and mergers [4] - The notification encourages equal treatment of various ownership enterprises, supporting private companies in revitalizing existing assets through REITs [4] Group 5: Market Ecosystem Improvement - The notification emphasizes the need to improve the issuance and trading mechanisms of REITs, optimizing market-oriented valuation and pricing mechanisms [5] - It highlights the importance of enhancing information disclosure and market constraints related to REITs [6] - The notification calls for the acceleration of legislative and regulatory frameworks to strengthen the legal foundation for high-quality REITs market development [6]

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has issued a notification to promote the high-quality development of the Real Estate Investment Trusts (REITs) market, emphasizing the importance of commercial real estate REITs in revitalizing existing assets and enhancing direct financing in the capital market [1][3]. Group 1: Market Development - The notification highlights that the development of commercial real estate REITs is a crucial measure to implement the central government's policies aimed at revitalizing existing assets and optimizing new growth [3]. - It encourages the issuance of commercial real estate REITs that align with policy directions and possess commercial attributes, promoting asset combinations that are complementary in function [3][4]. - The notification mandates that regulatory bodies enhance policy promotion and asset cultivation, while securities exchanges improve listing review efficiency and market service quality [3][4]. Group 2: Market Expansion - The notification calls for an increase in the supply of quality REITs and the improvement of fundraising systems and market pricing mechanisms [4]. - It supports the inclusion of REITs in investment scopes for public funds and encourages the development of innovative products like REITs ETFs [4]. - The notification aims to attract long-term funds from insurance, social security, and pension funds into the market, promoting REITs as part of the Shanghai-Hong Kong Stock Connect [4]. Group 3: Market Ecosystem Improvement - The notification emphasizes the need to optimize market-oriented valuation and pricing mechanisms for REITs, ensuring compliance in promotional and pricing activities [5]. - It outlines the establishment of a multi-tiered REITs market system and the improvement of registration processes to enhance efficiency and transparency [5][6]. - The notification stresses the importance of a comprehensive regulatory framework covering all aspects of REITs, including due diligence, pricing, trading, and information disclosure [6]. Group 4: Regulatory and Risk Management - The notification requires the establishment of a full-chain regulatory system to monitor asset quality, operational management, and governance levels [6]. - It mandates that regulatory bodies conduct daily supervision and risk management, while industry associations enhance self-regulation [6]. - The notification also highlights the need for investor education and market environment improvement to ensure stable market operations [6].

Group 1 - The core viewpoint of the article is the official announcement by the China Securities Regulatory Commission (CSRC) regarding the pilot program for commercial real estate investment trusts (REITs), marking the entry of commercial real estate into the public REITs era [1] - The announcement consists of eight articles that clarify product definitions, fund registration and operational management requirements, the roles of fund managers and professional institutions, and the strengthening of regulatory responsibilities [1] - In 2023, the market saw a total of 20 new product issuances and 5 expansions, raising a total of 47.335 billion yuan, leading to a total issuance scale of over 210 billion yuan in the domestic public REITs market by the end of the year [1] Group 2 - Over the past five years, China's REITs market has grown to become the largest in Asia and the second largest globally [1]

1. Report Industry Investment Rating - No information provided on the report industry investment rating. 2. Core Viewpoints - The launch of commercial real - estate investment trust funds (REITs) pilot is a significant step. Infrastructure REITs' successful exploration has provided valuable experience. It is an important part of the multi - level REITs market, helps the real - estate industry transform from "sales - oriented" to "operation - oriented", and is expected to make the market more rational for investors [2][10][19]. - Last week, most credit - bond yields declined slightly, but the decline was less than that of government - developed bonds, leading to a passive increase in credit spreads. Credit - bond net financing decreased slightly, and the issuance interest rates showed mixed trends. In secondary trading, medium - and short - duration bonds were actively traded, while long - duration bond trading remained at a low level [3][21][51]. 3. Summary by Directory Credit Hotspots: New Regulations and Outlook for Commercial Real - Estate REITs - On November 28, 2025, the CSRC issued the "Announcement on Launching the Pilot of Commercial Real - Estate Investment Trust Funds (Draft for Comment)". Commercial real - estate REITs are closed - end publicly - offered securities investment funds that invest in commercial real - estate asset - backed securities to obtain ownership or operating rights, and distribute most of the income to fund - share holders [2][10][20]. - China's REITs market started in the infrastructure sector. As of December 19, 2025, 78 REITs had been listed, raising 211 billion yuan with a total market value of 214.1 billion yuan. The underlying assets cover eight categories [10]. - The underlying asset scope of infrastructure REITs has gradually expanded, from consumer infrastructure to commercial real - estate REITs, with multiple relevant policies issued over the years [10][11][12]. - The structure of commercial real - estate REITs may refer to previous public REITs, with the CSRC and exchanges likely to be the review departments. The approval may speed up, and the long - term market space is expected to exceed 10 trillion yuan. It is of great significance to the multi - level REITs market, real - estate enterprises, and investors [19]. Market Review: Most Credit - Bond Yields Declined, and Credit Spreads Rose Passively - From December 12 to December 19, 2025, the tax - period capital market was stable, bond - fund redemptions briefly disrupted the market, and the expectation of LPR interest rate cuts resurfaced. Most credit - bond yields declined by about 2BP, and most Tier - 2 and perpetual bonds (except 1 - year) also declined by about 2BP, but less than government - developed bonds, causing spreads to rise passively. The 1 - 5Y varieties' spreads mostly rose by 2 - 3BP [3][21]. - Last week, wealth - management products had a net purchase of 37.6 billion yuan, and funds had a net purchase of 8.2 billion yuan. The scale of credit - bond ETFs was 528.2 billion yuan, a 3.73% increase from the previous week [3][21]. - In terms of industry spreads, the median spreads of public bonds of AAA - rated entities in various industries mostly rose by about 3BP last week, and the median spreads of public urban - investment bonds in each province generally rose by 2 - 4BP, with Yunnan and Guizhou rising by more than 6BP [3][21]. Primary Issuance: Credit - Bond Net Financing Declined Slightly, and Issuance Interest Rates Showed Mixed Trends - From December 15 to December 19, 2025, the total issuance of corporate - type credit bonds was 251.9 billion yuan, a slight 8% decline from the previous week; the total issuance of financial - type credit bonds was 100.4 billion yuan, a 40% decline [51]. - Among corporate - type credit bonds, urban - investment bonds issued 79.1 billion yuan, and industrial bonds issued 170.8 billion yuan. The total net financing was 47.3 billion yuan, a 34% decline from the previous week. Urban - investment net financing was 1.4 billion yuan, and industrial bond net financing was 49.7 billion yuan [51]. - For financial - type credit bonds, commercial - bank bonds had a net repayment of 35.2 billion yuan, commercial - bank sub - bonds had a net financing of 42 billion yuan, and insurance and securities - company bonds had a net financing of 10.5 billion yuan [51]. - Regarding issuance interest rates, the average issuance interest rate of medium - and short - term notes showed an upward trend except for AAA - rated ones, and the average issuance interest rate of corporate bonds showed a downward trend except for AA + - rated ones [51]. Secondary Trading: Medium - and Short - Duration Bonds Were Actively Traded, and Long - Duration Bond Trading Remained at a Low Level - Active trading entities were mainly medium - and high - grade, medium - and short - term, central - and state - owned enterprises. Urban - investment bond trading entities were mainly divided into two types: mainstream high - grade platforms in economically strong provinces and core platforms in regions with relatively high spreads in large economic provinces [5][61]. - Real - estate bond trading entities were still mainly AAA - rated, with trading terms mostly between 1 - 3 years; private - enterprise bond trading entities were also mainly AAA - rated, with medium - and short - term trading terms [5][61]. - In the long - duration bond market, there were no transactions of urban - investment bonds with a term of more than 5 years, remaining at a low level compared to the previous week [5][61].

Group 1 - The first batch of North Exchange 50 index funds has achieved positive returns since their launch three years ago, with the highest return reaching 66.65% [1] - The investment value of the North Exchange 50 index is expected to become more prominent as the number and scale of listed companies on the North Exchange continue to grow [1] - Quantitative dividend index enhancement strategies are gaining popularity among private equity institutions, becoming a mainstream allocation tool to meet diverse investor needs [1][6] Group 2 - A significant number of fund managers are facing salary reductions due to poor performance, with a new regulatory guideline linking compensation to long-term performance [6][7] - Over 1,400 active equity products have underperformed their benchmarks by more than 10 percentage points over the past three years, indicating a shift towards a long-term incentive mechanism in the public fund industry [7] - The public fund industry has seen a high turnover of executives, with 434 changes in leadership positions this year, raising questions about the impact of new leadership on industry dynamics [7] Group 3 - The consumer sector has struggled to keep pace with the A-share market's growth, with many funds heavily invested in consumer stocks facing losses [8] - Fund fee reforms are leading to a "20-80" phenomenon, where 20% of low-fee funds attract significantly more net inflows compared to the remaining 80% [8] - The private equity market is witnessing a surge in new fund registrations, with over 1,200 private securities investment funds registered in November, reflecting optimism about equity assets [9] Group 4 - Private equity firms are maintaining high positions in their portfolios despite market fluctuations, with stock private equity positions reaching 82.97%, a new high for the year [9] - The transformation of broker asset management products into public offerings is entering a critical phase, with a focus on compliance with regulatory requirements by the end of 2025 [10] - The introduction of commercial real estate investment trusts (REITs) is expected to enhance the financing channels for commercial real estate, leveraging the large existing market in China [10]

Group 1 - The core viewpoint of the news highlights the recent positive performance of the brokerage sector, with several stocks showing gains and significant inflows into the brokerage ETF [1][7] - The brokerage ETF (512000) has seen a net inflow of 1.021 billion yuan over the past five days, leading among 14 similar ETFs [1][7] - The China Securities Regulatory Commission (CSRC) has initiated a pilot program for commercial real estate investment trusts (REITs), which is expected to enhance the efficiency of capital markets in serving the real economy [3][9] Group 2 - The merger and acquisition activities in the securities industry are accelerating, with China International Capital Corporation planning to absorb Dongxing Securities and Xinda Securities through a share swap [3][9] - The securities industry is experiencing improved market conditions and high trading activity, benefiting from a new round of capital market reforms, which suggests significant growth potential for brokerages [3][9] - The average price-to-book (PB) ratio for the securities industry is projected to be 1.2x for 2025, maintaining a "buy" rating for the sector [3][9] Group 3 - The top ten weighted stocks in the brokerage index tracked by the ETF include prominent firms such as Eastmoney, CITIC Securities, and Huatai Securities [4][10] - The ETF and its linked fund are designed to passively track the performance of the securities company index, indicating a broad representation of the sector [4][10]

Report Summary 1. Report Industry Investment Rating No information provided. 2. Core Views - On November 28, the liquidity was ample, the bond market recovered, and the main indices of the convertible bond market rose collectively, with most convertible bond issues rising. The yields of US Treasuries across all tenors generally increased, while the yields of 10-year government bonds in major European economies showed divergent trends [1]. 3. Summary by Directory I. Bond Market News - **Domestic News** - In November, the manufacturing PMI was 49.2%, up 0.2 percentage points from the previous month; the non-manufacturing business activity index was 49.5%, down 0.6 percentage points from the previous month. The PMI of medium-sized enterprises was 48.9%, up 0.2 percentage points from the previous month, and the PMI of small enterprises was 49.1%, up 2.0 percentage points from the previous month, reaching a six-month high [3]. - The central bank will continue to adhere to the prohibitive policy on virtual currency and continuously combat illegal financial activities related to virtual currency [3]. - The CSRC solicited public comments on the "Measures for the Implementation of Regulatory Measures in the Securities and Futures Markets (Draft for Comment)", clarifying the procedural regulations for regulatory measures and improving the standardization of supervision and the level of governing the market by law [4]. - The CSRC solicited public comments on the "Announcement on the Pilot Program of Commercial Real Estate Investment Trust Funds (Draft for Comment)", including product definition, fund registration and operation management requirements, and strengthening regulatory responsibilities [5]. - **International News** - Tokyo's core inflation data in November exceeded market expectations, pushing the Bank of Japan closer to a second interest rate hike. The 11-month Tokyo core CPI rose 2.8% year-on-year, slightly higher than the market expectation of 2.7%. Japan's industrial output in October increased by 1.4% month-on-month, exceeding market expectations [6]. - **Commodities** - On November 28, WTI January crude oil futures fell 0.17% to $58.55 per barrel, Brent February crude oil futures fell 0.8% to $62.38 per barrel, COMEX December gold futures rose 1.27% to $4,218.3 per ounce, and NYMEX natural gas prices rose 4.92% to $4.863 per ounce [7]. II. Liquidity - **Open Market Operations** - On November 28, the central bank conducted 301.3 billion yuan of 7-day reverse repurchase operations at a fixed interest rate, with an operating rate of 1.40%. There were 375 billion yuan of reverse repurchases maturing on the same day, resulting in a net withdrawal of 73.7 billion yuan [9]. - **Funding Rates** - On November 28, the liquidity was ample. DR001 decreased by 0.81bp to 1.303%, and DR007 increased by 2.04bp to 1.467% [10]. III. Bond Market Dynamics - **Interest Rate Bonds** - **Spot Bond Yield Trends** - On November 28, the bond market recovered. As of 20:00 Beijing time, the yield of the 10-year Treasury active bond 250016 decreased by 1.50bp to 1.8290%, and the yield of the 10-year CDB active bond 250215 decreased by 1.85bp to 1.8990% [13]. - **Bond Tendering** - The 3-year "25进出清发007 (Additional Issue 16)" was issued with a scale of 1.5 billion yuan, a winning yield of 1.6505%, a full - subscription multiple of 7.59, and a marginal multiple of 1.58 [15]. - **Credit Bonds** - **Secondary Market Transaction Anomalies** - On November 28, the transaction prices of 9 industrial bonds deviated by more than 10%. "22万科MTN004" fell by more than 72%, "23万科01" fell by more than 71%, and "21万科04" fell by more than 67%; "22万科06" rose by more than 58%, "22万科04" rose by more than 74%, and several other bonds also had significant price increases [15]. - **Credit Bond Events** - Vanke mortgaged 15.3211 million shares of Vanke Property Service to Shenzhen Metro [16]. - China Jinmao obtained a medium - and long - term loan quota of 9.9 billion yuan, secured by the property rights of Century Avenue 88 - story building and its corresponding land use rights [16]. - Far East Development's revenue in the six months ended September 30 was approximately HK$3.756 billion, a year - on - year decrease of 27.38%, and the attributable loss to shareholders was HK$988 million, a year - on - year increase of 28.38% [16]. - **Convertible Bonds** - **Equity and Convertible Bond Indices** - On November 28, the three major A - share indices closed higher. The Shanghai Composite Index, Shenzhen Component Index, and ChiNext Index rose by 0.34%, 0.85%, and 0.70% respectively, with a total turnover of 1.6 trillion yuan. The main indices of the convertible bond market rose collectively, with a turnover of 65.18 billion yuan, an increase of 10.235 billion yuan from the previous trading day [17][19]. - **Convertible Bond Tracking** - On November 28, Lanfan Convertible Bond announced that the board of directors proposed to lower the conversion price; Changhong Convertible Bond and Lepu Convertible Bond 2 announced that they were about to trigger the conditions for lowering the conversion price. Zhongqi Convertible Bond announced an early redemption; Huamao Convertible Bond and Xinhua Convertible Bond announced that they were expected to trigger early redemption conditions [22]. - **Overseas Bond Markets** - **US Bond Market** - On November 28, the yields of US Treasuries across all tenors generally increased. The yield of the 2 - year US Treasury rose by 2bp to 3.47%, and the yield of the 10 - year US Treasury rose by 2bp to 4.02%. The 2/10 - year US Treasury yield spread remained unchanged at 55bp, and the 5/30 - year US Treasury yield spread remained unchanged at 108bp. The 10 - year US Treasury Inflation - Protected Securities (TIPS) breakeven inflation rate remained unchanged at 2.23% [21][23][24]. - **European Bond Market** - On November 28, the yields of 10 - year government bonds in major European economies showed divergent trends. The yield of the 10 - year German government bond rose by 1bp to 2.69%, while the yields of 10 - year government bonds in France, Italy, and Spain remained unchanged, and the yield of the 10 - year UK government bond fell by 1bp [25]. - **Daily Price Changes of Chinese - Issued US Dollar Bonds** - As of the close on November 28, bonds of companies such as Pinduoduo, Ctrip Group, and Lenovo Group had price increases, while bonds of companies such as Zhongjun Group Holdings, NIO, and Wanda Real Estate had price decreases [27].

Core Viewpoint - The public REITs market in China is evolving with a "first issuance + expansion" dual-driven development model, indicating a growing trend in the expansion of public REITs and the introduction of new investment categories [1][4][6] Group 1: Market Expansion and Developments - As of December 3, 2023, a total of 78 public REITs have been established in China, with 9 of them approved for expansion [1][4] - The recent expansion of the Huaxia Fund's rental housing REIT signifies the ongoing growth of public REITs, with an expected fundraising amount of approximately 1.1385 billion yuan [3][4] - The expansion methods for public REITs include offerings to unspecified objects and targeted offerings, enhancing market participation [3][4] Group 2: Investment Opportunities and Asset Types - The total scale of public REITs reached 182.399 billion yuan by the end of Q3 2025, covering various asset types such as logistics, environmental protection, and rental housing [6] - The introduction of commercial real estate REITs is anticipated to broaden the investment categories, with the China Securities Regulatory Commission drafting guidelines for this initiative [6][7] Group 3: Benefits of Expansion - Expansion of public REITs is expected to enhance fund scale, diversify risks, and improve cash distribution stability, ultimately providing more robust long-term returns for investors [5][8] - The increase in share supply post-expansion is likely to boost trading activity, while quality projects can achieve cross-regional and cross-industry expansion, improving operational efficiency [5][8]

Group 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].