New Rules for Private Fund Information Disclosure - An Observation from m88 casino bonus code Private Securities Fund Manager Perspective

In February 2026, m88 casino bonus code China Securities Regulatory Commission (CSRC) issued m88 casino bonus code Measures for m88 casino bonus code Supervision and Administration of Information Disclosure of Private Investment Funds (m88 casino bonus code“Information Disclosure Measures”), which will come into effect on September 1, 2026. m88 casino bonus code Information Disclosure Measures constitutes an important ancillary rule for m88 casino bonus code implementation of m88 casino bonus code Regulation on m88 casino bonus code Supervision and Administration of Private Investment Funds (m88 casino bonus code“Private Fund Regulation”). Compared with m88 casino bonus code previous regulatory framework, which was based on industry self-regulatory rules, m88 casino bonus code Information Disclosure Measures improves m88 casino bonus code regulatory regime in terms of legislative hierarchy, scope of application, disclosure requirements and legal liabilities, and impose clearer and more stringent information disclosure obligations on private fund managers.

By summarizing m88 casino bonus code key provisions of m88 casino bonus code Information Disclosure Measures, this briefing analyzes several issues requiring particular attention by private securities fund managers.

I. Elevation of m88 casino bonus code Legal Hierarchy of m88 casino bonus code Rules

Previously, information disclosure of private funds was mainly governed by self-regulatory rules issued by m88 casino bonus code Asset Management Association of China, such as m88 casino bonus code Measures for m88 casino bonus code Administration of Information Disclosure of Private Investment Funds. m88 casino bonus code newly issued Information Disclosure Measures is promulgated by m88 casino bonus code CSRC in m88 casino bonus code form of departmental rules, m88 casino bonus codereby elevating m88 casino bonus code legal hierarchy of m88 casino bonus code provisions. m88 casino bonus code superior legal basis of m88 casino bonus code Information Disclosure Measures has been adjusted from m88 casino bonus code Interim Measures for m88 casino bonus code Supervision and Administration of Private Investment Funds to m88 casino bonus code Private Fund Regulation. m88 casino bonus code elevation of m88 casino bonus code legislative hierarchy means that information disclosure requirements have been upgraded from self-regulatory rules to administrative regulation, and regulatory enforcement is expected to be strengm88 casino bonus codened accordingly.

II. Expansion of m88 casino bonus code Scope of Applicable Entities

m88 casino bonus code Information Disclosure Measures expands m88 casino bonus code scope of applicable entities. In addition to private fund managers and custodians, private fund distribution agencies and om88 casino bonus coder private fund servicing institutions are also brought within m88 casino bonus code scope of information disclosure supervision, m88 casino bonus codereby covering whole process of private fund operations.

m88 casino bonus code Information Disclosure Measures also introduces a new requirement that shareholders, partners and actual controllers of private fund managers shall cooperate in fulfilling information disclosure obligations. This provision strengm88 casino bonus codens compliance obligations after see-through to m88 casino bonus code equity ownership of private fund managers.

With respect to custodians, m88 casino bonus code Information Disclosure Measures references m88 casino bonus code institutional framework of m88 casino bonus code Measures for m88 casino bonus code Administration of Custody Business of Securities Investment Funds, which is applicable to public funds. It integrates and clarifies m88 casino bonus code information disclosure obligations of custodians and requires custodians to conduct necessary verification of information such as m88 casino bonus code financial status of funds. We note that m88 casino bonus code Measures for m88 casino bonus code Supervision and Administration of Custody Business of Commercial Banks (Trial), which came into effect on February 1, 2026, impose same requirement on commercial banks that provide custody services.

III. Introduction of “Timeliness” Requirement and Voluntary Disclosure

m88 casino bonus code Information Disclosure Measures provides that disclosure shall follow m88 casino bonus code principles of truthfulness, accuracy, completeness and timeliness. Timeliness has been included as a disclosure standard, emphasizing that managers should disclose information to investors within a reasonable period so that investors are kept informed of m88 casino bonus code funds’ operation.

m88 casino bonus code Information Disclosure Measures establishes a model combining mandatory disclosure and voluntary disclosure. In addition to m88 casino bonus code information required to be disclosed by law, managers may also conduct voluntary disclosures as needed. Such voluntary disclosures shall still comply with m88 casino bonus code fundamental principles of truthfulness and accuracy, shall not contain misleading statements, and shall not constitute disguised false publicity.

IV. Increased Disclosure Frequency with Extended Deadlines for Quarterly Reports

m88 casino bonus code Information Disclosure Measures does not require private securities investment funds to submit monthly reports. However, it requires that m88 casino bonus code disclosure frequency of m88 casino bonus code share net asset value and cumulative share net asset value of open-ended private securities investment funds shall not be lower than m88 casino bonus code frequency of fund opening. This means that, upon m88 casino bonus code implementation of m88 casino bonus code Information Disclosure Measures, private securities fund managers shall disclose m88 casino bonus code share net asset value and cumulative share net asset value of all m88 casino bonus codeir open-ended private securities funds to investors in accordance with m88 casino bonus code opening frequency stipulated in m88 casino bonus code fund contract, regardless of m88 casino bonus code fund’s asset size. For example, if m88 casino bonus code fund contract provides that m88 casino bonus code fund opens once per week, m88 casino bonus code net asset value information shall be disclosed to investors on a weekly basis. Closed-ended private securities investment funds shall disclose fund net asset value information to investors at least once per quarter.

m88 casino bonus code Information Disclosure Measures adjusts m88 casino bonus code disclosure deadline for quarterly reports, extending it from m88 casino bonus code previous 10 working days to one month. This adjustment, to a certain extent, alleviates m88 casino bonus code time pressure on managers in preparing information disclosures.

m88 casino bonus code Information Disclosure Measures specifies that when a major event occurs, m88 casino bonus code manager shall prepare an ad hoc report and disclose it to investors within five working days from m88 casino bonus code date of m88 casino bonus code occurrence of m88 casino bonus code major event. Compared with m88 casino bonus code previous principle-based requirement of timely disclosure, m88 casino bonus code new rules have introduced a clear time limit.

V. Introduction of See-through Disclosure and Expanded Major Event Disclosure Requirements

With respect to m88 casino bonus code content of periodic reports, m88 casino bonus code Information Disclosure Measures introduces a see-through disclosure requirement. Where private securities investment funds invest in om88 casino bonus coder private funds or lawfully launched asset management products (excluding publicly offered securities investment funds), m88 casino bonus code manager shall disclose not only m88 casino bonus code information on its own invested assets, but also m88 casino bonus code investment path of each layer and m88 casino bonus code underlying assets identified through see-through. For fund-of-funds (FOF) products, m88 casino bonus code regulatory authorities may furm88 casino bonus coder refine requirements through additional rules in m88 casino bonus code future.

With respect to m88 casino bonus code content of ad hoc reports, m88 casino bonus code Information Disclosure Measures add several scenarios for major events disclosure, including m88 casino bonus code convening of fund unit holder meetings, partner meetings or shareholders’ meetings and m88 casino bonus code matters resolved m88 casino bonus codereby. If a major adverse event occurs in respect of a fund’s primary investment target and has a material negative impact on investors’ rights and interests, m88 casino bonus code manager shall, in m88 casino bonus code ad hoc report, explain m88 casino bonus code reasons and provide risk warnings to investors. We understand that managers may assess whem88 casino bonus coder a major adverse event exists by considering whem88 casino bonus coder changes in m88 casino bonus code primary investment target may materially affect m88 casino bonus code fund’s net asset value, investment returns, exit arrangements, capital safety or om88 casino bonus coder aspects.

Currently m88 casino bonus codere is no mandatory audit requirement for contractual-type private securities funds with custodians. m88 casino bonus code Information Disclosure Measures specifies that where a private securities fund falls into any of m88 casino bonus code following categories, its annual financial statements shall be audited by an accounting firm filed with m88 casino bonus code CSRC: (i) m88 casino bonus code fund mainly invests in illiquid assets; (ii) m88 casino bonus code fund mainly invests in derivatives; (iii) m88 casino bonus code fund mainly invests in overseas assets (excluding direct investments in overseas standardized assets); (iv) m88 casino bonus code fund mainly invests in private funds managed by om88 casino bonus coder private fund managers; or (v) om88 casino bonus coder circumstances prescribed by m88 casino bonus code CSRC. This means that QDLP funds adopting a feeder-master fund structure will be required to conduct annual audits after m88 casino bonus code Information Disclosure Measures takes effect.

VI. Upgrading Internal Governance and Record Retention Requirements

m88 casino bonus code Information Disclosure Measures requires private fund managers and custodians to establish and improve information disclosure management policies. m88 casino bonus codese policies shall not only include mechanisms for handling investor inquiries relating to information disclosure but shall also introduce a policy specifically for m88 casino bonus code management of non-public information. While responding to reasonable investor information requests in a timely manner, managers shall also ensure that m88 casino bonus code entire process of information transmission remains secure and controllable.

m88 casino bonus code Information Disclosure Measures extends m88 casino bonus code minimum retention period for information disclosure materials from 10 years to 20 years after m88 casino bonus code completion of fund liquidation and requires dedicated departments and senior management personnel designated responsible for record management. This significantly increases m88 casino bonus code requirements for information retention and internal management.

After m88 casino bonus code Information Disclosure Measures takes effect, m88 casino bonus code obligations and retention periods for private fund managers regarding m88 casino bonus code preservation of information and records will be as follows:

VII. Administrative Liability for Information Disclosure Violations

m88 casino bonus code Information Disclosure Measures contains a separate chapter on supervision and legal liabilities, specifying that m88 casino bonus code CSRC and its dispatched offices have m88 casino bonus code authority to supervise m88 casino bonus code information disclosure activities of private fund managers, custodians, distribution agencies and servicing institutions. Regulatory authorities may impose administrative supervisory measures such as ordering rectification, conducting regulatory interviews and issuing warning letters in accordance with m88 casino bonus code law. Violations of information disclosure obligations may also be subject to administrative penalties pursuant to m88 casino bonus code Private Fund Regulation and om88 casino bonus coder applicable laws and regulations.

Prior to this, administrative penalties for violations relating to private fund information disclosure were mainly imposed by m88 casino bonus code CSRC pursuant to Article 56 of m88 casino bonus code Private Fund Regulation and Article 38 of m88 casino bonus code Interim Measures for m88 casino bonus code Supervision and Administration of Private Investment Funds. m88 casino bonus code issuance of m88 casino bonus code new measures furm88 casino bonus coder improves m88 casino bonus code legal basis for penalties and regulatory enforcement actions.

VIII. m88 casino bonus code “New-Old Cut” Principle

With respect to m88 casino bonus code implementation arrangements, m88 casino bonus code Information Disclosure Measures adopts m88 casino bonus code regulatory principle of “New - Old Cut”. From September 1, 2026, when m88 casino bonus code Information Disclosure Measures officially takes effect, newly filed private funds shall comply with m88 casino bonus code provisions of m88 casino bonus code Information Disclosure Measures regarding fund contracts and om88 casino bonus coder terms. For existing private funds, it is not mandatory to amend m88 casino bonus code fund contract immediately. However, in case of any change to m88 casino bonus code fund contract in this regard, m88 casino bonus code changed sections are required to comply with m88 casino bonus code Information Disclosure Measures.

IX. Next Step – Our Recommendations

Private fund managers are recommended to complete m88 casino bonus code following preparatory work before m88 casino bonus code Information Disclosure Measures comes into effect:

1. Review m88 casino bonus code information disclosure provisions in existing fund contracts, or update fund contract templates togem88 casino bonus coder with custodians, to ensure compliance with m88 casino bonus code Information Disclosure Measures;

2. Revise and improve information disclosure policies, designate specialized departments and senior management personnel responsible for information disclosure matters, confirm m88 casino bonus code workflow and internal control mechanisms to ensure information disclosure is truthful, accurate, complete and timely, introduce mechanisms for handling investor inquiries on information disclosure, revise retention periods for disclosure-related materials, and introduce accountability mechanisms for failure to disclose information as required;

3. Establish a non-public information management policy;

4. Improve m88 casino bonus code management and preservation of information disclosure archives;

5. Confirm whem88 casino bonus coder m88 casino bonus code private funds under management fall within m88 casino bonus code scope requiring mandatory audits.

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