Port communicationWhat are the requirements for applying for an asset allocation license? August 29, 2025，The Asset Management Association of China released "Answers to Questions and Answers Related to Registration and Filing of Private Equity Funds"(fifteen)》,On the basis of the previous three types of managers such as private equity fund managers，Added Category 4—Private Asset Allocation Fund Managers,Private asset allocation fund managers and private asset allocation funds are finally here。 What exactly is a private equity asset allocation fund manager?
We need to start with what a private asset allocation fund is。According to the "Definition and Description of Business Types" in the reporting platform，Private asset allocation funds refer to securities investments that mainly use fund-of-funds investment methods.、Equity and other cross-category asset allocation investments，80%The above invested fund assets should be invested in registered private equity funds、Publicly offered funds or other asset management products established in accordance with the law。
It can be seen from this，Asset allocation funds mainly have two characteristics:，First，Private asset allocation fund managers can invest across categories，No longer limited to securities or equity，The Fund Industry Association has repeatedly emphasized the professional management of each manager.，This is a major breakthrough，Asset allocation funds can choose stocks、Equity、trust、fund、Investment in various ways such as income rights and other combinations，and no proportional restrictions；second，80%The above invested fund assets should be invested in registered private equity funds、Publicly offered funds or other asset management products established in accordance with the law，Only no more than 20% of the quota can be directly invested in investment targets，Investment model similar to FOF，Compared with FOF funds，The largest private equity asset allocation fund
Advantages
The first point is that it is not restricted by the scope of investment.。
Recently, a manager came to ask some questions about asset allocation managers.，Hong Kong Xintong-share it with everyone，These are also some of the major issues currently faced by managers when applying for asset allocation, for your reference.。
At least one of the institutions controlled by the same actual controller has become an ordinary member of the Asset Management Association of China (hereinafter referred to as the "Association")；Or the institutions controlled by the same actual controller include at least one private equity fund manager that has been registered with the association for more than three years.，The average annual private equity fund management scale of the manager in the past three years is not less than 500 million yuan.，And has become an observer member of the association。
The main points are just two points： ①Ordinary members can apply； ②Association observation members，The manager has been registered for more than three years，The management scale in the past three years is not less than 500 million yuan。There is no conflict between being established for three years and observing membership.，No
Require
It must have been observed by members for three years.，I hope everyone will pay attention to this。 3、Do asset allocation managers still need to “protect the shell”?
According to the "Announcement on Further Regulating Certain Matters concerning the Registration of Private Equity Fund Managers" issued by the Association on February 5, 2025： two、 Regarding strengthening information submission
Require
(1) Private equity fund managers shall promptly register private equity funds in accordance with the law. In order to achieve effective supervision of private equity fund managers，Supervise registered private equity fund managers to operate in accordance with the law，Timely filing of private equity fund products，The Asset Management Association of China requires private equity fund managers to timely register private equity funds in accordance with the law.
Require
： 1、 From the date of this announcement，A newly registered private equity fund manager has not registered its first private equity fund product within 6 months from the date of completing the registration procedures.，The Asset Management Association of China will cancel the registration of the private equity fund manager。
Not in the announcement，And the association's "Q&A 15" treats "shell protection" differently.。Therefore, it is recommended that managers apply for asset allocation managers，It is still necessary to register the first private equity fund product within 6 months.。
4、Difficulties in applying for asset allocation Difficulties in applying for asset allocation，Just three o'clock：①Personnel issues: The applicant institution should have no less than two full-time senior managers with more than three years of asset allocation experience.，Or have no less than two people with more than five years of relevant experience in domestic and overseas asset management (such as investment research、Marketing、operations、Full-time senior managers with working experience in compliance risk control or asset management regulatory agencies or self-regulatory organizations, etc.。
The association does not have a clear definition of asset allocation or domestic and overseas asset management.，Therefore, this still needs to be understood by the managers themselves.。Find a capable person，Fully able to comply with the association
Require
personnel。 ②Problems of benefit transfer: asset allocation managers and existing managers of actual controllers，Will there be transfer of benefits?，how to avoid。Is the company system perfect?，Is the risk control capability strong enough?。This is what the legal opinion should describe in detail。
③ Compliance issues of managers under the name of the actual controller. The actual controller may have a private equity management organization under his name.，The association may conduct a similar self-examination inquiry to private equity managers other than the applicant institution.。
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