在股市升温以及监管层引导中长期资金入市的背景下，凭借相对稳健的业绩表现，量化私募基金获得保险 资金的青睐。 由于险资直接投资私募的路径尚未获得监管明确，因此通过私募MOM（管理人中管理人）模式进行"绕道"投 资成为部分险资机构的选择，这也直接推动私募MOM产品的发展。根据记者统计，2025年备案数量创下历史 新高。 过去一年新增备案的产品，其母基金管理人主要为券商资管、期货。然而，记者从多位券商资管人士处交叉核 实获悉，私募MOM产品新增备案已被叫停，主要因为监管担忧该业务在实践中可能异化为"通道"，偏离主动 管理。 担忧沦为通道业务 一直以来，市场持续关注保险资金"借道"私募MOM布局量化策略。（ 详见《调查｜险资"灰色"投资私募量 化，中小险企借道MOM试水》 ）但这一业务已被悄然按下"暂停键"。 "叫停至少有三个月了，至今没有恢复。"深圳一家中小券商资管人士向记者表示。中国证券投资基金业协会 （以下简称"协会"）公开信息显示，自2025年9月2日协会新增备案一批私募MOM产品后，再无新的私募MOM 产品备案记录。 谈及原因，多名券商资管人士均向记者表明，监管担心私募MOM业务"通道化"。华北地区一家中小 ...

Group 1 - The rapid development of private MOM products is highlighted, with 29 products registered by May 20 this year, surpassing the total of 23 for the entire year of 2024 and setting a new record since 2019 [2] - MOM (Manager of Managers) is defined as a unique investment management model that involves delegating investment advice to multiple qualified third-party asset management institutions, allowing for diversified asset allocation [2] - Compared to FOF (Fund of Funds), MOM offers advantages in investment concentration limits, rebalancing flexibility, and the authority of the parent fund [3] Group 2 - The implementation of the "MOM Product Guidelines" by the CSRC at the end of 2019 has led to a more regulated environment for MOM products, allowing securities and futures asset management to engage in private MOM business [3] - Many of the newly registered MOM products are structured with cooperative institutions (such as securities and futures asset management) as trustees, and multiple private fund managers as investment advisors [3] - There is a growing demand for diversified allocation from bank wealth management and insurance asset management, especially as interest rates decline and volatility increases [3] Group 3 - Despite the advantages, there are risks associated with outsourced investments, which require strong research and investment capabilities [4] - The performance of MOM products heavily relies on the management capabilities of private funds as investment advisors and the selection and risk control measures of the funding parties [4] - Recent incidents, such as the collapse of a major FOF private institution, have led some bank wealth management firms to suspend similar channel businesses due to associated risks [4] Group 4 - The use of FOF and MOM tools is not merely a simple investment choice; it requires robust quantitative algorithms and detailed due diligence to select suitable products and managers [5] - Wealth management subsidiaries are adopting outsourcing as a long-term investment strategy, but there is still a need for improvement in the research and investment capabilities related to FOF and MOM [5]