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私募基金管理人的备案审批流程

私募基金管理人备案私 募投资基金管理人登记和私募基金备案不属于行政许可事项

According to the Securities Investment Fund Law、"Notice of the Central Organization Office on the Division of Responsibilities for Private Equity Fund Management"、中国证监会授权以及 《私募投资基金管理人登记和基金备案办法(试行)》(以下简称办法)有关规定,The Asset Management Association is responsible for the registration of private investment fund managers and the filing of private equity funds.,并 履行行业自律监管职能。Self-regulatory management of private equity funds centers on information disclosure,Based on honesty and trustworthiness。

Private equity fund managers promise to ensure the authenticity of the information provided、Legal responsibility for accuracy and completeness。基 金业协会对于私募投资基金管理人提供的登记备案信息不进行实质性事前审查。Investors must make careful judgments and identify risks when investing in private equity funds。

1、Private investment funds (hereinafter referred to as private equity funds),Refers to investment funds established by raising funds from qualified investors in a non-public manner,Including companies or partnerships established for the purpose of investment activities whose assets are managed by fund managers or general partners。2、Registration method:Submit information online through electronic systems,Online review。

3、登记流程4、Registration information content:Fill in the basic information of the fund manager、Basic information for senior managers and other practitioners、Basic information of shareholders or partners、Basic information about managed funds。5、Registration time limit:Complete materials,The Fund Industry Association shall within 20 working days from the date of receipt of all registration materials.,Disclose the basic information of private equity fund managers through the website,Complete registration procedures for private equity fund managers。

6、Announcement content:Name of private equity fund manager、Establishment time、Registration time、address、Contact information、Basic information such as the main person in charge and basic integrity information。7、Unregister:经登记后的私募基金管理人依法解散被依法撤销或者被依法宣告破产的基金业协会应当及时注销基金管理人登记。–深圳吾思已被注销登记

8、私募基金备案时点:The private equity fund manager shall notify the public within 20 working days after the private equity fund is raised,Filing through the private equity fund registration and filing system,And indicate the fund category based on the main investment direction of the private equity fund.,Fill in the fund name truthfully、Capital size、investor、Fund contract (fund company articles of association or partnership agreement,(hereinafter collectively referred to as the fund contract) and other basic information。

Corporate funds employ self-employed management teams to manage fund assets,While the corporate fund is undergoing registration procedures as a fund,,You also need to complete the registration procedures as a fund manager。9、Registration time limit for private equity funds:Private equity fund registration materials are complete and comply with

Require

of,The Fund Industry Association shall within 20 working days from the date of receipt of all filing materials,Disclose the basic information of private equity funds through the website,Complete registration procedures for private equity funds。

The basic information of private equity funds published on the website includes the name of the private equity fund.、Establishment time、Filing time、Main investment areas、Fund manager and fund custodian and other basic information。提供的一站式备案注册管理公司→实收注册资本→私募基金投资管理人备案从事私募证券投资基金业务的各类私募基金管理人,All its senior managers should obtain fund professional qualifications。

Various private equity fund managers engaged in non-private securities investment fund business,At least two senior executives should obtain fund practice qualifications。Based on current filing practices,Private equity funds (without distinguishing between equity or securities, etc.)

Require

Two qualified executives are sufficient。且若在提交法律意见书时还没有取得从业资格的不妨碍提交备案申请但要承诺在2025年12月31日取得从业资格

otherwise,根据我们的理解在其他条件都符合的情况下协会将可能予以通过备案但会限制基金管理人发行产品

(依据 2025年3月23日中国基金业协会在上海举办《关于进一步加强私募基金管理人登记<公告>政策培训》时主讲人中国基金业协会私募会员部主任董煜韬指出“已登记且尚未备案私募基金产品的私募基金管理人目前高管人员尚不具备从业资格的仍可补提《私募基金管理人登记法律意见书》后先发产品但高管人员必须在2025年12月31日前取得从业资格法律意见书中对于高管人员的从业资格情况及考试报名情况等如实披露即可可发表保留意见”)

Senior executives of private equity fund managers meet one of the following conditions:,Can obtain fund practitioner qualifications:(1) Pass the Fund Practitioner Qualification Examination;(2) Obtain professional qualifications through relevant certifications。(1) Engaged in investment management-related business in the past three years and meet relevant qualification requirements。Such situations mainly refer to those who have engaged in asset management-related business in the past three years.,And the average annual scale of assets under management is more than 10 million yuan。

(2) Passed the Securities Practitioner Qualification Examination、Futures Practitioner Qualification Examination、Banking qualification examination and meet relevant qualification requirements;Or pass the Certified Public Accountant Qualification Examination、Legal Professional Qualification Examination、Asset appraiser professional qualification examination and other financial-related qualification examinations and meet relevant qualification requirements。

It is proposed to adopt the above paragraph (1)、(2) Method of determination of circumstances: Senior executives of private equity fund managers who have obtained fund practice qualifications,You should also pass the Fund Practitioner Qualification Examination Subject 1 "Fund Laws and Regulations"、Professional Ethics and Business Standards" exam,Only then can it be determined that the fund practitioner qualification has been obtained。

(3) Senior managers of private equity investment fund managers (including venture capital fund managers) who meet one of the following conditions,You can apply to the Qualification Certification Committee of the China Asset Management Association for recognition of fund business qualifications.:a. Engaged in private equity investment (including venture capital) for 6 years or more,And participate in and successfully exit at least two projects;b. Served as a senior manager of a listed company or a large or medium-sized enterprise with a paid-in capital of not less than 1 billion yuan,And have been in the industry for 12 years or more;c. Senior managers who have been engaged in economic and social management for 12 years or more;d.In colleges and universities、Research institutions engaged in economics、12 years or more of teaching and research in finance and other related majors,and obtain the title of professor or researcher。

(3) Meet one of the above conditions,Submit the following materials to the China Asset Management Association by your institution or individual:(1) Application form for personal qualification certification;(2) Basic personal information registration form。

(四)相关证明材料(1)符合上述条件a的,Proof of successful exit from participating projects and two recommendation letters signed by industry celebrities are required.,The recommendation letter should include the recommender’s title and contact information.;(2)符合上述条件b的需提交企业和个人的相关证明和两份行业知名人士署名的推荐信,The recommendation letter should include the recommender’s title and contact information.;(3)符合上述条件c的需提交有关组织部门出具的任职证明(4)符合上述条件d的需要提交相关资格证书和两份行业知名人士署名的推荐信,The recommendation letter should include the recommender’s title and contact information.。

资格认定委员会构成及工作机制资格认定委员会由中国证券投资基金业协会理事(不含非会员理事)监事及私募基金相关专业委员会委员构成每次从上述委员中随机抽取七人组成认定小组小组成员对申请资格认定的人员以简单多数原则表决

参与资格认定的表决人推荐人及资格认定结果将通过中国证券投资基金业协会网站的从业人员信息公示平台向社会公示


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