国家金融监督管理总局发布《资产管理信托管理办法》

The Measures reinforce the private placement nature of these products, capping investors at 200 and requiring strict adherence to 'seller due diligence, buyer beware' principles. Compliance teams must immediately review product structures to ensure compliance with qualified investor criteria and non-public offering rules. The regulation places heavy emphasis on risk management, mandating robust frameworks for operational risk, concentration risk, related party transactions, and liquidity risk.

Firms should assess their current risk controls and enhance systems to meet these standards. Sales practices are also under scrutiny: trust companies must eliminate any principal or return guarantees, improve risk disclosure, and formalize key processes such as document signing and risk assessments. Investment management requirements prohibit channel business and fund pools, require portfolio investment, and demand penetration management for investments in other asset management products.

This may necessitate restructuring of certain products and increased due diligence on underlying assets. Net value management and disclosure are tightened: separate accounting per product, adherence to accounting standards, and annual external audits for products with non-standard assets and natural person investors. This will increase operational complexity and compliance costs but also enhance transparency and investor confidence.

Trust companies should prepare for heightened supervision by updating policies, training staff, and conducting gap analyses. While the Measures may reduce some high-risk or non-compliant business lines, they also present opportunities to strengthen market position through robust compliance and investor trust. Overall, this is a significant regulatory shift requiring prompt action from compliance and business teams.