1. Report Industry Investment Rating No relevant content provided. 2. Core Views of the Report - The report compares the characteristics of fund information disclosure between China and the US, aiming to provide reference for the construction of China's fund information disclosure system [1][7]. - The regulatory frameworks of the two countries are similar, but the regulatory concepts have different focuses. China's information disclosure is more guided by regulations, focusing on protecting the interests of ordinary investors, while the US is more market - driven, emphasizing market fairness and efficiency [5][8]. - The disclosure styles also vary. China's disclosure is concise and efficient, while the US's is more comprehensive, detailed, and has a higher frequency, especially in portfolio disclosure [5][8]. - Suggestions are put forward for China's information disclosure system, including transforming the disclosure concept, improving the accountability mechanism, and enhancing the disclosure of fund positions, transactions, and different share information [5]. 3. Summary According to the Directory 3.1 Sino - US Fund Information Disclosure Comparison 3.1.1 Regulatory System and Concept - The regulatory frameworks of China and the US are similar, with the local securities regulatory commissions as the main regulatory bodies, top - level laws, and a series of supporting regulations [8]. - In terms of regulatory concepts, both aim to maintain the orderly development of the capital market and are friendly to investors. However, due to differences in capital market development stages, market participants, and judicial accountability systems, China focuses on regulatory guidance and protecting ordinary investors, while the US focuses on market demand and information transparency [5][8][9]. 3.1.2 Main Disclosure Documents - China requires the disclosure of 17 types of fund information, including the prospectus, fund contract, and regular reports. The US requires the disclosure of registration - related documents, regular operation reports, and other documents such as proxy voting records [13][14]. 3.1.3 Information Disclosure Characteristics - **Disclosure Granularity and Frequency**: The US disclosure is more comprehensive, detailed, and has a higher frequency, especially in portfolio disclosure. As of mid - 2025, US mutual funds disclose their full portfolio details quarterly, and from the end of 2025, most will disclose monthly. China discloses the top 10 heavy - holding stocks, etc. quarterly and adds full stock and asset - backed securities portfolios semi - annually [16]. - **Hierarchical Disclosure**: The US uses hierarchical disclosure more widely and maturely. For example, the prospectus has three versions, and the shareholder reports have a simplified version for retail investors. In China, most disclosure documents are in one version, and the "Fund Product Information Summary" can be regarded as a simplified version of the prospectus [19][20]. 3.2 Sino - US "Prospectus" Information Disclosure Comparison 3.2.1 Relevant Regulations and Sample Selection - China's regulations for prospectus disclosure are the "Content and Format of the Prospectus" under the "Securities Investment Fund Information Disclosure Content and Format Guidelines No. 5", and the US is the "N - 1A (Registration statement for mutual funds and ETFs)". The sample funds selected are the "Invesco Great Wall Strategy Selective Allocation Hybrid Fund" in China and the "Franklin Global Allocation Fund" in the US [22][23]. 3.2.2 Comparison: Investment Strategy - China's disclosure requirements for investment strategies are relatively broad, while the US's are more specific, requiring the disclosure of certain strategies such as concentrated strategies and temporary defensive strategies [27]. 3.2.3 Comparison: Performance - Both countries require the disclosure of long - term fund performance. China requires the disclosure of risk - return characteristics, while the US does not. In terms of presentation, China presents the comparison between fund net value growth rate and performance benchmark return rate more intuitively, and the US presents the past 10 - year return more intuitively [27][28][29]. 3.2.4 Comparison: Fees - Both countries require the disclosure of fund management fees, custody fees, etc. China explains fee details in text and formulas, while the US uses tables to list different share fees and shows the total fees in different years through examples. The US also requires the disclosure of the impact of portfolio turnover on fees, which is not mandatory in China [35][36]. 3.2.5 Comparison: Subscription and Redemption - China highlights the impact of "large - scale subscription and redemption", while the US emphasizes the impact of "frequent subscription and redemption" [37]. 3.2.6 Comparison: Different Fund Share Situations - China's disclosure of different fund share information is relatively scattered, while the US recommends providing a centralized and understandable comparison of different share information [38][42]. 3.2.7 Comparison: Risk Warning - China's risk disclosure requirements are more specific, clearly listing the types of risks to be disclosed. The US's requirements are more general but emphasize the risk of improper sales caused by paying commissions to intermediaries, which is rarely mentioned in China [44][45]. 3.3 Summary and Enlightenment - In general, China and the US both aim to maintain the orderly development of the capital market, but have different regulatory concepts and disclosure styles. In the prospectus, China focuses on risk disclosure, and the US focuses on the impact of "frequent trading" and "conflicts of interest". - Suggestions for China include transforming the disclosure concept, promoting the implementation of the securities class - action system, increasing the disclosure of fund positions, transactions, and different share information [46][48][50].