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 ...

南方财经全媒体记者 孙诗卉 实习生 徐若萱 上海报道 11.39万亿元的资产管理信托市场，正在向保险机构敞开大门。 近日，国家金融监督管理总局发布《资产管理信托管理办法（征求意见稿）》，明确保险公司可代销资 产管理信托。这一政策不仅打破了保险机构代销信托的资格限制，更推动了保险业从传统产品销售向综 合财富管理转型。 "这意味着保险行业财富管理业务的一次战略性升级。"对外经济贸易大学创新与风险管理研究中心副主 任龙格接受21世纪经济报道记者采访时指出。 保险代销信托开闸 2025年10月31日，国家金融监督管理总局发布《资产管理信托管理办法（征求意见稿）》（下称"《办 法》"），其第35条明确规定，允许商业银行、理财公司、保险公司、保险资产管理公司等机构代理销 售信托产品。 这一规定是对今年初政策的延续与完善。 2025年1月27日，国务院办公厅转发金融监管总局《关于加强监管防范风险推动信托业高质量发展的若 干意见》的通知，第五条要求"规范（信托）销售行为，严格代销管理，严禁非金融机构代销信托产 品。" 此次《办法》则进一步明确了金融机构代销资产管理信托的细则，放开了保险机构代销信托产品的资格 限制。 中国信托 ...

Core Viewpoint - The release of the "Asset Management Trust Management Measures (Draft for Comments)" marks a significant regulatory upgrade for the trust industry, aiming to address structural issues and promote high-quality development in asset management [1][2]. Group 1: Transformation Goals of the Trust Industry - The trust industry aims to achieve three main transformation goals: clarify the legal positioning of asset management trusts, break the rigid repayment mechanism, and standardize investment operations to enhance professional asset management capabilities [2][3]. Group 2: Comprehensive Regulatory Framework - The Measures establish a comprehensive regulatory framework covering product positioning, establishment conditions, sales management, investment operations, risk control, and information disclosure [4]. - The Measures define asset management trusts as "private asset management products based on trust legal relationships," reinforcing the independence of trust property and severing the basis for rigid repayment [4][5]. Group 3: Investor Protection and Risk Management - A strict investor suitability management system is introduced, with specific requirements for investor qualifications and minimum investment amounts, enhancing preemptive investor protection [5][6]. - The Measures prohibit various business forms that deviate from the essence of asset management, including channel business and fund pool operations, aiming to eliminate past profit models that contributed to systemic risks [6][8]. Group 4: Industry Dynamics and Future Outlook - The Measures will accelerate the restructuring of trust companies' business models, leading to a potential short-term contraction in asset management scale but opening opportunities for standardized securities investment and family trusts [8][10]. - The industry is expected to shift from a "scale-oriented" approach to one focused on "capability," resulting in increased market concentration and the exit of underperforming firms [10][11]. - Trust companies will need to compete with other asset management institutions under unified regulatory rules, necessitating strategic positioning to leverage their strengths while addressing weaknesses [11].

Core Viewpoint - The recent release of the "Asset Management Trust Management Measures (Draft for Comments)" by the National Financial Supervision Administration aims to enhance regulation and risk prevention in the trust industry, marking a significant shift towards quality development and true asset management functions [1][2]. Regulatory Framework - The new measures consist of five chapters and eighty-five articles, clearly defining asset management trusts as private asset management products based on trust law relationships [1]. - The principles of "seller responsibility, buyer self-responsibility" are emphasized, prohibiting channel business, fund pool operations, and rigid repayment [1][2]. - The measures align with previous regulations, such as the "Asset Management New Regulations," to eliminate rigid repayment, multi-layered nesting, and introduce independent custody mechanisms [3]. Investor Standards and Sales Management - The measures significantly upgrade the standards for qualified investors, raising the investment threshold for individual investors and introducing requirements for institutional investors [2][3]. - Sales management is more stringent, with clear regulations on sales methods, documents, and institutions, and a prohibition on any form of capital preservation promises [3][4]. Investment Management Requirements - The measures outline strict management of trust assets, requiring clear legal relationships and adherence to specified investment ranges [4]. - Different asset categories must be managed distinctly, and investment cooperation institutions must meet specific qualifications [4]. Business Model Transformation - The new regulations signify a shift from a financing-driven model to an investment-driven model, requiring trust companies to focus on professional investment management capabilities [5][6]. - Revenue models will transition from fixed expected returns to net value fluctuations, compelling trust companies to enhance their investment research capabilities [5][6]. Industry Dynamics - The introduction of these measures is expected to lead to increased competition, with leading institutions leveraging research and resource advantages to capture market share [6]. - Smaller institutions may need to focus on niche areas or face consolidation or market exit, leading to higher industry concentration [6].

Core Viewpoint - The National Financial Regulatory Administration has released a draft regulation aimed at standardizing the development of asset management trust businesses, emphasizing "returning to the essence and strictly controlling risks" [2] Summary by Sections Regulation Overview - The draft regulation consists of five chapters and eighty-five articles, highlighting clear prohibitions on channel and fund pool businesses, marking the end of the "no-risk arbitrage" model in the trust industry [2] - The regulation establishes a comprehensive framework for product establishment, sales, operations, risk management, information disclosure, and supervision, creating a "four-dimensional risk prevention" system [2] Definition and Investor Requirements - The regulation defines asset management trusts as private asset management products based on trust law, aimed at qualified investors who can identify and bear risks [4] - It sets stringent requirements for qualified investors, including a minimum net financial asset threshold of 3 million RMB for individuals and 10 million RMB for institutions [6] Prohibition of Channel and Fund Pool Businesses - The regulation explicitly prohibits channel and fund pool operations, requiring trust companies to fulfill active management responsibilities and not delegate these duties to other entities [7] - It mandates that trust companies must accurately reflect the net value of trust units and adhere to the actual income and risk factors of underlying assets [7] Investment Management and Control - The regulation limits the investment amount in a single asset to no more than 25% of the trust product's actual trust capital, with an overall cap of 30 billion RMB for all trust products managed by a company [8] - It encourages the development of standardized trust products while reducing the proportion of non-standard products, pushing trust companies to transition from "financing intermediaries" to "investment management institutions" [6][8] Transitional Arrangements and Compliance - Trust companies are required to review existing asset management trust businesses and develop rectification plans in accordance with the new regulation, with progress monitored by the regulatory authority [10]

Core Viewpoint - The recent draft of the "Asset Management Trust Management Measures" marks a shift towards a more refined regulatory framework for the trust industry, addressing the need for updated regulations after 18 years of existing rules, and emphasizing the importance of returning to the core functions of trust services [1][2] Regulatory Framework - The draft further clarifies the boundaries of asset management trusts, emphasizing private asset management characteristics, limiting investor numbers to a maximum of 200, and enforcing stricter qualifications for high-risk products [2] - It prohibits any form of guaranteed returns, mandating that sellers are responsible for their actions and buyers bear their own risks, thus breaking the previous rigid repayment structure [2] - The draft also bans channel business and fund pool operations, requiring trust companies to manage assets actively and transparently [2] Challenges in Non-standard Assets - The draft imposes strict limitations on non-standard asset investments, which may lead to a decrease in financing trusts and pressure on companies reliant on non-standard business models [3] - Trust companies are urged to enhance their research capabilities and operational structures to meet the new demands for standardized products and net asset value management [3] Opportunities for Growth - The draft opens avenues for high-quality development in the trust industry, with standardized trusts expected to become a key focus area [4] - Trust companies can leverage regulatory flexibility to create differentiated products, such as family trusts and insurance fund mandates, to compete with public funds and securities asset management products [4] - The asset securitization sector presents significant potential, with trusts benefiting from bankruptcy isolation features in areas like REITs and supply chain ABS [4] Service Trusts as a Growth Driver - Service trusts, including family trusts and charitable trusts, are anticipated to become a growth area, as they do not rely on capital consumption and can attract high-net-worth clients [5] - The regulatory authority will monitor the progress of asset management trust business rectifications, encouraging companies to reduce existing business volumes and transition into professional investment management [5]

Core Viewpoint - The "Asset Management Trust Management Measures (Draft for Comments)" was released by the National Financial Supervision Administration, aiming to strengthen regulatory requirements for asset management trusts and delineate new red lines for various business practices [1][2]. Group 1: Background and Purpose - The current regulations for trust companies have been in place since 2007 and require adjustments to align with industry practices. The new measures are a response to previous regulations established in 2018 and 2023, aiming to enhance supervision and risk prevention in the trust industry [3]. - The draft aims to solidify the regulatory framework for the healthy development of asset management trusts [3]. Group 2: Structure and Content of the Measures - The draft consists of five chapters and 85 articles, covering general principles, product establishment, operational management, supervision, and definitions [4]. - It defines asset management trusts as private asset management products based on trust law, emphasizing the need for active management and adherence to market principles [5]. Group 3: Sales Requirements - Trust companies must clearly disclose risks to investors and cannot guarantee returns or obscure actual risk conditions. There are strict requirements for risk disclosure and sales management [7]. - Trust companies are required to assess the risk tolerance of individual investors and match them with appropriate products [7]. Group 4: Investment Management Requirements - Trust companies must manage trust assets legally and transparently, adhering to specified investment scopes and managing different asset categories distinctly [8]. - There are limits on the proportion of single asset investments within trust products [8]. Group 5: Risk Management and Information Disclosure - A comprehensive risk management system must be established, covering various types of risks, including operational, credit, market, and liquidity risks [9]. - Information disclosure requirements are detailed, ensuring transparency in trust asset management [9]. Group 6: Regulation of Key Business Areas - The draft prohibits channel business and fund pool operations, mandating that trust companies take active management responsibility for their products [10]. - It also sets strict guidelines for related party transactions, requiring accurate identification and regulation of such transactions [10]. Group 7: Rectification of Existing Trust Business - Trust companies are required to review existing asset management trust businesses against the new measures, develop rectification plans, and ensure orderly reduction of non-compliant business scales [11].

Group 1: Policy and Financial Instruments - The National Development and Reform Commission (NDRC) announced that 500 billion yuan of new policy financial instruments have been fully deployed within a month, driving project investments of approximately 7 trillion yuan [1] - The central government has allocated 500 billion yuan in local government debt limits, with 200 billion yuan designated as new special bond quotas to expedite project construction and physical work volume [1] Group 2: Fund Management Regulations - The China Securities Regulatory Commission (CSRC) is seeking public opinion on the draft guidelines for performance benchmarks of publicly raised securities investment funds, emphasizing the importance of stable investment styles and internal control mechanisms [2] - The guidelines aim to standardize the use of performance benchmarks in fund management, including salary assessments and fund evaluations [2] Group 3: Asset Management Trust Regulations - The draft Asset Management Trust Management Measures has been released, marking the first specialized management measures for asset management trusts since the 2018 regulations [4] - The new measures require alignment of sales assessments with bank wealth management regulations and the establishment of independent custody "firewalls" to mitigate industry risks [4] Group 4: Local Government Financing and Debt Management - The Ministry of Finance emphasizes the need for a unified long-term regulatory system for local government debt and strict accountability for illegal borrowing practices [5] - The focus is on optimizing debt structures and establishing a sustainable government debt management mechanism that aligns with high-quality development [5] Group 5: Monetary Policy and Market Dynamics - The People's Bank of China (PBOC) is expected to adopt more flexible approaches in its bond buying operations to ensure market stability and support fiscal policies [8] - The bond market has shown signs of recovery, with long-term interest rates stabilizing, although uncertainties remain regarding future market conditions [8] Group 6: Bond Market Performance - In September, the bond market issued a total of 81,027.8 billion yuan across various categories, including government bonds and corporate credit bonds [7] - The bond market is experiencing fluctuations, with many listed banks reporting declines in non-interest income due to bond market volatility [8]

Core Viewpoint - The National Financial Regulatory Administration has released a draft for public consultation on the "Asset Management Trust Management Measures," aiming to standardize the development of asset management trust businesses in line with the central financial work conference's directives [1] Group 1: Asset Management Trust Positioning - The draft positions asset management trusts as private asset management products based on trust legal relationships, emphasizing their alignment with the essence of asset management [1] - Trust companies are required to prioritize the legitimate interests of investors, adhering to the principle of "seller's responsibility, buyer's risk; seller's negligence, legal compensation" [1] - Comprehensive management practices must be implemented, including suitability management, sales management, investment management, asset custody, net value management, and information disclosure [1] Group 2: Private Placement and Investor Standards - The draft maintains a private placement orientation, stating that trust products are to be issued non-publicly to qualified investors, with a maximum of 200 participants [1] - Stricter investor standards are to be enforced for high-risk trust products, building on the asset management new regulations regarding investor qualifications and minimum investment amounts [1] - Trust companies must adhere to suitability management procedures during the sales and transfer of trust products [1]

Core Viewpoint - The National Financial Regulatory Administration has released a draft regulation aimed at standardizing the development of asset management trust businesses, emphasizing enhanced supervision and risk prevention [1][2]. Summary by Sections Regulation Overview - The draft regulation, titled "Asset Management Trust Management Measures (Draft for Comments)," consists of five chapters and eighty-five articles [1]. - The main objectives include clarifying product positioning, strengthening overall management, enforcing strict sales management, enhancing investment management, and improving risk management and information disclosure [1]. Compliance and Rectification - Trust companies are required to review their existing asset management trust businesses in accordance with the new regulations, identify areas needing rectification, and develop a remediation plan with a clear timeline [1]. - The progress of rectification will be a key basis for classified supervision, ensuring that trust companies address issues in an orderly manner [1]. - For asset management trust businesses that fall under the transitional period of the new asset management regulations, continued rectification is mandated according to previous submissions [1]. Next Steps - The National Financial Regulatory Administration plans to revise and finalize the draft regulation based on public feedback before implementation [2].