[Text/Observer Network Wang Kaiwen] The war in the Middle East continues to rage, and the Strait of Hormuz, a global energy artery, is in a de facto blockade. This situation has roiled the global energy market, and India, which is highly dependent on Middle East energy, feels the pain particularly strongly. but
When 55 cities around the world are vying to develop a low-level economy, former US President Biden bluntly said that this is "a war that the United States cannot afford to lose." However, in this world-class competition, China has already quietly run a different rhythm?
In "This Is China" broadcast on March 9, the host He Jie, Professor Zhang Weiwei, Dean of the China Institute of Fudan University, and Ren He, a distinguished expert from COMAC and director of the Shanghai General Aviation Association Expert Committee, conducted an in-depth dialogue, revealing the development status and core advantages of China's low-altitude economy, and also allowing us to see clearly China's confidence in the global competition.
In the program, Ren He made it clear that by 2024, 55 cities around the world have joined the low-altitude economic layout, including 6 cities in the United States and 8 cities in Australia. Brazil, South Korea, Japan and European countries have also made efforts to integrate low-altitude aircraft into daily life. Morgan Stanley even predicts that by around 2035, 35% of intercity transportation will be replaced by high-speed rail and cars by small planes, completely changing human travel patterns.
In the face of fierce competition on a global scale, Professor Zhang Weiwei used China's actual practice to give the answer: the earliest low-altitude test line from Suzhou Kunshan to Pudong Airport in China has been running stably for a year. The flight only takes 25 minutes, while traditional driving takes 2 hours, which greatly saves travel time. Especially for passengers who need to depart from Pudong Airport, this low-altitude route completely solves the pain points of time-consuming and prone to congestion on ground transportation. It has shown great practicality in the Yangtze River Delta region and has become a vivid example of the implementation of China's low-altitude economy.
From the competition among global leaders to the steady implementation of China's practice, China has not blindly followed the trend, but is practical-oriented, allowing the low-altitude economy to truly serve people's livelihood, and has blazed its own solid path in the global race.
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Announcement code:2026-003
Announcement of Tianjin Motianm Technology Group Co., Ltd. on the resignation of the company’s non-independent directors
The company and all members of the board of directors guarantee that the information disclosed is true, accurate and complete, and contains no false records, misleading statements or major omissions.
1. Resignation of non-independent directors
The board of directors of Tianjin Motian Membrane Technology Group Co., Ltd. (hereinafter referred to as the "Company") today received a written resignation report from the company's non-independent director Mr. Zheng Chunjian. Mr. Zheng Chunjian resigned as a director of the company due to personal work arrangements. His original term was until the expiration of the fifth session of the board of directors (i.e. January 16, 2028). After resigning as a director, Mr. Zheng Chunjian no longer holds any other positions in the company.
According to relevant regulations such as the Company Law, Shenzhen Stock Exchange Self-Regulatory Guidelines for Listed Companies No. 2 - Standardized Operations of GEM Listed Companies, and the Articles of Association, Mr. Zheng Chunjian’s resignation did not cause the company’s board of directors to fall below the legal minimum number of members and did not affect the normal operation of the company’s board of directors. The resignation report took effect from the date it was delivered to the board of directors.
As of the date of this announcement, Mr. Zheng Chunjian does not directly or indirectly hold shares of the company, and there are no commitments that should be performed but have not been performed. The company and the board of directors express their sincere gratitude to Mr. Zheng Chunjian for his contribution to the development of the company during his tenure as director of the company.
2. Documents available for inspection
1. Mr. Zheng Chunjian’s “Resignation Letter”
Announcement is hereby made.
Board of Directors of Tianjin Motian Membrane Technology Group Co., Ltd.
March 16, 2026
However, according to multiple foreign media reports, Iran has recently begun to allow some Indian ships to pass through the Strait of Hormuz. In this regard, Indian Foreign Minister Jaishankar said that this proves that India's diplomatic efforts have "produced results."
According to a report by the Financial Times on March 16, Jaishankar confirmed in an interview that two liquefied petroleum gas carriers flying the Indian flag passed through the Strait of Hormuz on March 14.
"I am currently in dialogue with them and my dialogue has yielded some results," Jaishankar said. "The dialogue is still continuing and if it yields results, I will naturally move forward."
"From India's perspective, it's better to reason, work together and find a solution than no solution at all," he added.
According to Reuters, the two liquefied petroleum gas carriers are Shivalik and Nanda Devi, carrying about 92,700 tons of liquefied petroleum gas.
Indian Foreign Minister S Jaishankar Press Trust of India
Last week, international oil prices exceeded US$100 per barrel for the first time since August 2022, and are still hovering at this price. Some industry analysts expect oil prices may continue to rise if the conflict continues.
The Strait of Hormuz is the only waterway from the Persian Gulf to the outside world. More than a quarter of the world's total seaborne oil and about one-fifth of the world's liquefied natural gas transportation are shipped to all parts of the world through the Strait of Hormuz.
Iran's Supreme Leader Mujtaba Khamenei emphasized in his speech on the 12th that Iran should continue to use the "leverage method" of "closing" the Strait of Hormuz to put pressure on Iran's enemies.
The Financial Times stated that European countries, including France and Italy, have begun dialogue with Iran to discuss possible diplomatic solutions to restore energy transportation.
Iranian Foreign Minister Araghchi said in an interview with CBS on the 15th that Iran is open to countries that want to discuss "the safe passage of their ships."
According to Reuters, Iranian Ambassador to India Mohammad Fatali confirmed to the Indian media on the 14th that Tehran has allowed some Indian ships to pass through the Strait of Hormuz.
It is worth mentioning that Jaishankar was interviewed before going to Brussels to attend the EU Foreign Ministers' Meeting. The meeting will discuss whether to expand the EU's "Operation Aspid" in the Red Sea to the Strait of Hormuz.
"Operation Aspid" was launched in February 2024 to protect commercial ships in the Red Sea, Gulf of Aden and surrounding waters from attacks by Yemen's Houthi armed forces. It currently consists of three warships sent by France, Italy and Greece.
Asked whether European countries could emulate India's arrangement, Jaishankar said: "Frankly, every relationship to some extent has to work on its own terms. So, it's difficult for me to compare this to other relationships that may or may not have similar conditions."
"I am happy to share what we are doing with EU countries, and I know many countries have also had conversations with Tehran." Jaishankar said.
He revealed that there is no "unified arrangement" between India and Iran for ships flying the Indian flag, and "the passage of each ship is handled individually on a case-by-case basis."
Jaishankar also denied that Iran had obtained quid pro quo in the process, emphasizing that the "long history of dealings between the two sides... is the basis for my contacts."
"This is not a question of quid pro quo. India and Iran have maintained contacts. And we think this conflict is very unfortunate." Jaishankar said.
He added that diplomatic efforts between India and Iran are at an early stage and we have more ships there. So while this is a welcome development, conversations continue and work is ongoing. "
According to Reuters, a spokesperson for the Indian Ministry of Foreign Affairs said on the 14th that after Iran allowed several Indian ships to pass through the Strait of Hormuz, India is seeking Iran to provide safe passage for 22 Indian ships stranded.
India is the world's fourth largest buyer of LNG and the second largest buyer of LPG. According to Reuters, India consumed 33.15 million tons of cooking gas last year, of which imports accounted for about 60%, 90% of which came from the Middle East.
The Indian government has asked domestic refineries to increase LPG production and cut sales to the industrial sector to ensure that household supplies are not affected.
Mujtaba Khamenei, 57, has not appeared in public since he was announced as Iran's new supreme leader.
While there are divergent opinions about Mujtaba's health, on March 15, the Kuwaiti media Al-Jarida reported that a source revealed that Mujtaba had been transferred to Moscow by a Russian military aircraft due to his health and safety. Mujtaba reportedly underwent a "successful" surgical operation upon arrival and is currently receiving treatment at a private hospital inside the presidential palace in Moscow.
On the 16th local time, when asked about "Mujtaba's treatment in Russia", Russian Presidential Press Secretary Peskov refused to comment.
This high-level source who is said to be close to Mojtaba told the newspaper that Mojtaba was injured in the "first round of air strikes" launched by the United States and Israel on Iran on February 28. His injuries require a well-equipped hospital, sophisticated medical tracking and special monitoring, but these conditions are difficult to achieve when Iran continues to suffer heavy bombing.
The person further explained that Iran's security agencies were worried that Mujtaba's location would be leaked to doctors and medical experts, so they agreed to the suggestion that he go to Russia for treatment.
According to this person, Russian President Vladimir Putin personally proposed to allow Mujtaba to be treated in Russia during a phone call with Iranian President Pezeshchiyan on March 6. Iranian officials, as well as Mujtaba himself, carefully discussed the proposal and ultimately agreed. That night, Mujtaba was transferred and treated by Russian doctors and several accompanying Iranian doctors.
In addition, the report also quoted sources from Iran and Israel.
An Iranian source said that some public opinion believes that Mujtaba's first speech was actually written by Ali Larijani, Secretary-General of Iran's Supreme National Security Council, because the content is highly consistent with the latter's previous public statements.
Israeli sources revealed that Israeli intelligence agencies believe Mujtaba's injuries may be more serious than initially estimated, adding that Tel Aviv has not yet obtained conclusive evidence that he has left Iran.
According to the Russian TASS news agency, at a press conference on the 16th, Peskov refused to comment on the rumors that "Mujtaba arrived in Moscow for treatment." He responded: "We do not comment on such reports."
Mujtaba data map Oriental IC
On the evening of March 8, local time, the Iranian Experts Conference issued a statement announcing the election of Mujtaba Khamenei, the son of the late Supreme Leader Ali Khamenei, as the new Supreme Leader of the Islamic Republic of Iran.
On the 12th, Mujtaba delivered his first speech since taking office, calling on the Iranian people to unite and emphasizing that Iran should continue to "close" the Strait of Hormuz to put pressure on Iran's enemies. Some Western media noticed that Mujtaba's first statement was read out by a news anchor. He did not appear on the scene. Iranian state television did not explain this.
Since he has never appeared in public, there has been speculation about Mujtaba's health.
The "Newspaper" disclosed on the 4th that Mujtaba was injured in a US-Israeli air strike, and the left side of his body was injured from his head to his feet. Reports say he escaped unhurt when debris from the building fell near Mujtaba rather than hitting him directly.
The British "Sun" quoted sources as saying that Mujtaba lost at least one leg, and also suffered serious damage to his stomach or liver, and his condition was "very serious." But "The Sun" pointed out that they could not verify the accuracy of the news.
Iranian Ambassador to Cyprus Salarian confirmed the news that Mujtaba was injured on the 11th. In an interview with the British "Guardian", he said that Mujtaba was a "survivor" of the first round of US-Israeli air strikes and had "injuries on his legs, hands and arms, and bruises on his eyes."
On the 13th, U.S. Defense Secretary Hegseth said that the United States had learned that Khamenei had been injured and was likely to be "disfigured." In response, Iranian Foreign Minister Araghchi responded on the 14th that there was "no problem" with Mujtaba's physical condition.
Recently, people in many countries around the world have held protests against the military actions launched by the United States and Israel against Iran.
U.K.
On the 15th local time, a protest rally against the military actions launched by the United States and Israel against Iran was held in London, England.
According to CCTV news, anti-war people at the scene shouted to stop air strikes on Iran and opposed the indiscriminate killing of innocent people. In order to prevent conflicts between people with different stances, the London Police deployed a large number of police forces at the scene. Demonstrators with different stances gathered on both sides of the Thames: on one side were tens of thousands of demonstrators supporting Iran and opposing the war, while on the other side there were only a few hundred people supporting the United States and Israel. The two sides faced off across the river, which was a sharp contrast in scale.
Demonstrator Sadid Ahmed Alwadaei: If you want to see the true face of the United States and Israel, just look at how many children they killed when they attacked the elementary school in the city of Minab, Iran. This reveals the true face of the West. I don’t think the United States and Israel are winning this war. We can see that Iran is firmly resisting the aggression of the United States and Israel.
Organizers stated that approximately tens of thousands of people participated in the anti-war protest that day. The London police deployed approximately 1,000 police officers to maintain order at the scene and temporarily closed nearby roads. London police said that a total of 12 people were arrested during the protest held in central London that day.
USA
On March 14, local time, protests broke out in Washington, USA. Some people held a rally in front of the White House to oppose the military action launched by the United States and Israel against Iran.
Protesters: I think it's especially important for Americans to take to the streets today because our government launched a missile attack on a girls' school in Iran. There is absolutely no excuse for this kind of behavior. Our government's behavior is evil. I hope Americans will take to the streets to express this and express our disapproval that we cannot support this evil behavior of our government.
Protester: As a people, I believe we have a responsibility to stand up against atrocities. Whether or not it affects you personally, hearing these things happening over and over again makes you want to speak out.
In Washington, some residents also said that since the United States and Israel used force against Iran, gasoline prices across the United States have also risen sharply, which has affected the lives of ordinary people. At the same time, people continue to question the legality of this military strike against Iran.
Local resident Brody: I definitely feel it. (Gas prices) have doubled. It’s crazy. I do not support the use of force by the United States and Israel against Iran at all. What I hear is (the US government) telling us that the reason for launching air strikes against Iran is because Iran will soon launch a nuclear war. But the U.S. government has been saying this for so many years without any evidence. The United States launched a preemptive strike against Iran without authorization from Congress, so I think this military action is baseless and completely unreasonable.
Israel
On the 14th local time, a large number of people held protests in Tel Aviv, Israel, to oppose the military strikes launched by the United States and Israel against Iran. The protesters said that this war was "stupid and unnecessary" and that the actions of the United States and Israel were "criminal acts" that have brought suffering to people in all countries.
Protester: I am against this war, I am against all wars. And this war is particularly bad, a completely criminal act, a lawless criminal act.
Protester: I cannot agree with what the Israeli government has done, nor with the appalling crimes against humanity committed by Israeli soldiers.
Protesters: This is a disaster for everyone, people are suffering in Iran, in Lebanon, in Israel. We (hold the event) want to send this message to all the people around the world who have suffered as a result of this senseless and unnecessary war.
Italy
On the 15th local time, Italian people held a protest outside the Sigonella base of the US military stationed in Sicily, Italy, calling on the Italian government to stop providing support for the US-Israeli military strike against Iran.
Demonstrators held flags high outside the Sigonella base to protest against the United States' use of Italian military bases to launch military operations against Iran.
Demonstrator Cosentino: This base is used by the US military to carry out military operations against Iran and facilitates the US-Israeli aggression against Iran. Many fighter planes and drones take off from here. Similarly, the US military also uses another base in Sicily to use satellite data to guide drones to carry out air strikes against Iran.
Demonstrator Irene: We call on the Italian government to take action against countries that use weapons to kill civilians and children.
Australia
On the 14th local time, a large number of Australians gathered outside Sydney City Hall to protest against the military strikes launched by the United States and Israel against Iran.
Outside Sydney Town Hall, demonstrators held high Iranian and Palestinian flags to protest against US and Israeli atrocities. Many people said that the military actions of the United States and Israel violated international law.
Demonstrators: We hope that the US and Israeli governments will immediately stop bombing Iran and stop the war unconditionally. They are hurting a lot of people, in fact, they are hurting the entire world. The US and Israel's strikes against Iran are completely illegal, but the two countries do not care whether they violate international law.
Demonstrators: We don’t need the United States to be the world’s policeman. The US-Israeli military attack on Iran has no basis in international law.
China provided $200,000 in aid to Iran. Ambassador to Iran: Attacking schools and harming children violates the bottom line of human moral conscience
The handover ceremony for the emergency humanitarian assistance of US$200,000 provided by the Red Cross Society of China to the Iranian Red Crescent Society was held on the 15th at the Chinese Embassy in Iran. This aid is specifically used to express sympathy and comfort to the families of the teachers and students who died in Shajare Tayebeh Primary School in Iran.
Chinese Ambassador to Iran Cong Peiwu said at the handover ceremony that China condemns all indiscriminate attacks on civilians and non-military targets. Attacks on schools and harming children are serious violations of international humanitarian law and violate the bottom line of human moral conscience. China is willing to continue to support the Iranian people in overcoming the difficulties. As a sincere friend and strategic partner of the Middle East countries, China is willing to work with the Middle East countries to implement global security initiatives and restore order to the Middle East, tranquility to the people, and peace to the world.
At the ceremony, Alishwandi, vice president of international affairs of the Iranian Red Crescent Society, thanked China for its assistance in Iran's difficult moments, saying that this fully demonstrated China's image as a responsible major country and the deep friendship between the two peoples to help each other.
On February 28, the first day that the United States and Israel launched a large-scale military operation against Iran, the Shajare Tayebe Primary School in Minab City, Hormozgan Province, southern Iran, was attacked. At least 165 people were killed, mostly little girls around 10 years old.
Preface
On December 30, 2025, the China Securities Regulatory Commission (hereinafter referred to as the "CSRC") reviewed and approved the "Measures for the Supervision and Administration of Information Disclosure of Private Investment Funds" (hereinafter referred to as the "New Information Disclosure Regulations"), which will be effective from September 1, 2026. As the upper-level regulatory rules in the field of private equity fund information disclosure, the Measures are based on the "Securities Investment Fund Law of the People's Republic of China" and the "Private Investment Fund Supervision and Administration Regulations" as the legislative basis, and systematically regulate the subject, content, method, affairs management and legal responsibilities of private equity fund information disclosure.
Back on February 4, 2016, the Asset Management Association of China (hereinafter referred to as the "China Asset Management Association") issued the "Private Investment Fund Information Disclosure Management Measures" (hereinafter referred to as the "Association Information Disclosure Measures"). As an industry self-regulatory rule, it initially established a self-regulatory regulatory framework for private equity fund information disclosure and played an important role in regulating the private equity industry's information disclosure behavior and protecting private equity investors' right to know. However, as the scale of the private equity fund industry expands, product structures become more complex, and cross-field investments increase, self-regulatory management alone is no longer able to meet the needs of industry development. The introduction of the new letter disclosure regulations has realized the transformation of private equity fund letter disclosure supervision from "self-discipline-led" to "collaboration of administrative supervision and self-discipline management", filling the gap in rules at the administrative supervision level.
This article combines the practical experience of the association’s letter disclosure methods and provides an in-depth interpretation of the new letter disclosure regulations from the aspects of rule positioning, core clause comparison, practical changes and compliance suggestions, etc., with a view to providing reference for the compliance operations of private equity fund managers, custodians, sales agencies and related entities, and assisting the high-quality development of the private equity industry.
1. From self-discipline and regulation to coordination of administrative supervision and self-discipline management
As an industry self-regulatory rule, the association's letter disclosure method can only be based on "industry self-discipline management". The management subject is limited to the China Foundation Association. The management methods are mainly disciplinary sanctions, such as conversation reminders, written warnings, industry censure, blacklisting, etc.
The new rules for information disclosure clarify the mechanism of "administrative supervision leading and self-regulatory management coordination", clarifying that the China Securities Regulatory Commission and its dispatched agencies are the main regulatory entities for private equity fund information disclosure, and they exercise supervisory and management powers in accordance with the law. The China Fund Association conducts self-regulatory management in accordance with laws, administrative regulations and self-regulatory rules. This change in positioning is mainly reflected in two aspects: First, it makes up for the shortcomings of the association's low-level rules and insufficient punishments in the association's letter disclosure regulations, and strengthens the rigid constraints of the letter disclosure rules by setting clear administrative supervision measures and administrative penalty clauses; second, it clarifies the division of labor and cooperation between administrative supervision and self-discipline management. The China Securities Regulatory Commission is responsible for macro supervision and violation penalties, and the China Association for Basic Law is responsible for daily self-discipline inspections and business guidance, forming a regulatory synergy.
From a practical point of view, this change in positioning further promotes the inclusion of private equity fund information disclosure into the scope of administrative supervision. The disclosure behavior of relevant entities must not only comply with the self-discipline requirements of the China Foundation Association, but also strictly abide by the administrative supervision regulations of the China Securities Regulatory Commission, otherwise they will face severe administrative liability.
2. Comparative interpretation of core terms
The new rules on information disclosure include seven chapters and 44 articles. Compared with the association's information disclosure methods, they are more complete in structure and more detailed in content. They focus on strengthening and improving information disclosure subjects, disclosure requirements, disclosure content, affairs management and legal responsibilities. Based on the relevant provisions of the association’s letter disclosure methods, we have a detailed comparative interpretation as follows:
(1) Expansion of scope and refinement of responsibilities of information disclosure entities
Article 2 of the Association’s Information Disclosure Measures stipulates that information disclosure obligors are private equity fund managers, private equity fund custodians, and other entities specified by laws, administrative regulations, the China Securities Regulatory Commission, and the China Asset Management Association. It does not clearly include private equity fund sales agencies within the scope of obligated entities. It only mentions “slandering other fund sales agencies” in the prohibited behaviors of information disclosure obligors, and does not provide specific provisions on their information disclosure responsibilities.
Article 2 of the new letter disclosure regulations clearly includes “private fund sales agencies accepting the entrustment of private fund managers to disclose private fund information to investors” within the scope of application. In addition, Article 32 of the new disclosure regulations also includes shareholders, partners, and actual controllers of private equity managers as subjects of cooperation obligations, requiring them to proactively inform relevant information and not to conceal or provide false information, nor to organize or instruct managers to violate the disclosure regulations.
Practical impact: In the case of entrusted sales, private equity fund sales agencies are the first step for investors to contact fund products, and their disclosure behavior directly affects investors' decisions. The new disclosure regulations clearly include private equity fund sales agencies as obligated subjects, filling the previous regulatory gap; at the same time, the new disclosure regulations clarify the cooperation obligations of managers, shareholders, and actual controllers, strengthening "penetrating supervision."
(2) Strengthening and refining the basic requirements for information disclosure
Article 4 of the Association's Information Disclosure Measures only requires the information disclosure obligor to ensure the "authenticity, accuracy and completeness" of the information, without mentioning "timeliness", and the requirements for disclosure methods, risk disclosure and other requirements are relatively principled.
Article 3 of the new information disclosure regulations adds "timeliness" requirements on the basis of "authenticity, accuracy and completeness", clarifying that information disclosure should be based on the interests of investors; Article 8 further requires managers to clarify the content, channels, methods and frequency of information disclosure in the fund contract, as well as the contact information for investors to consult on information disclosure matters, the emergency mechanism for managers unable to perform information disclosure obligations, and the contract stipulations must not be lower than legal requirements; Article Article 10 makes it clear that disclosures should be made in a non-public manner as agreed with investors, through mail, email, the website or mobile client of the specific object determination process, etc., to ensure that investors can obtain information in a timely manner, and the content of the same information disclosed through different channels should be consistent; Article 12 strengthens the risk disclosure requirements of managers, clarifying that complex and high-risk private equity funds need to disclose risks in a significant way, and inform investors to make prudent decisions and bear their own risks. In addition, Article 13 of the New Information Disclosure Regulations adds a new “penetrating disclosure” requirement, clarifying that if a private equity fund invests in other private equity funds, non-public asset management products, or invests through special purpose vehicles, the invested entity shall cooperate with the manager’s penetrating disclosure obligations. This is also an important measure to protect private equity investors’ right to know important investment-related information in multi-layer nesting situations.
Practical impact: Adding "timeliness" requirements forces managers to disclose on time to avoid damage to investors' rights due to delayed disclosure; clarifying the non-public disclosure method further strengthens the private nature of private equity funds and prevents disguised public disclosures; penetration disclosure requirements break multiple layers of nested information barriers, making it easier for regulatory authorities to grasp the true investment situation of the fund, and also for private equity investors to fully understand the direction of capital investment.
(3) Classification refinement and disclosure requirements upgrade of periodic reports
Articles 16 and 17 of the Association’s Information Disclosure Measures stipulate in principle the regular disclosure during the operation period of private equity funds, unify the quarterly disclosure and annual disclosure requirements for all private equity funds, and do not distinguish the differences between private securities investment funds, private equity investment funds and venture capital funds, and the disclosure content regulations are relatively general.
Chapter 3 of the new letter disclosure regulations specifically sets up a "periodic reporting" chapter, sets disclosure requirements according to fund type classification, and details the content, time limit and auditing requirements of regular disclosures, as follows:
Private securities investment funds: Article 18 of the new disclosure regulations stipulates that the net value disclosure frequency of open-end funds shall not be lower than the open frequency, and the net value of closed-end funds shall be disclosed at least once every quarter; Articles 19 and 20 clarify the specific contents of quarterly reports (disclosed within 1 month after the end of each quarter) and annual reports (disclosed within 4 months after the end of each year) that private equity fund managers should disclose, including the basic information of the fund, financial situation, investment group Article 21 clearly states that for private equity investment funds that mainly invest in liquidity-restricted assets, derivative assets, overseas assets (except for direct investment in overseas standardized assets), and other private equity funds managed by other private equity fund managers, the annual financial report must be audited by an accounting firm that complies with the Securities Law. Private equity investment funds: Articles 22 and 23 of the new disclosure regulations stipulate that private equity fund managers shall disclose the specific contents of semi-annual reports (disclosed within 2 months after the end of each half-year) and annual reports (disclosed within 6 months after the end of each year), including fund net assets and actual subscription information. status, investment targets, related transactions, project investment and exit status, etc.; Article 24 clarifies that annual financial reports must be audited by an accounting firm. Private equity investment funds with large management scale and a large number of natural person investors must be audited by an accounting firm that complies with the provisions of the Securities Law. Venture capital funds: Article 25 of the new disclosure regulations clarifies that the disclosure content, time and auditing requirements of annual reports shall be implemented with reference to the requirements of private equity investment funds.
In addition, Article 26 of the new disclosure regulations has added exceptions. If a private equity fund has been established for less than three months, it may not prepare periodic reports for the current period, in line with the actual situation of the industry.
Practical impact: Classified disclosure requirements are more in line with the operating characteristics of different types of private equity funds and avoid the compliance burden caused by "one size fits all"; the refinement of audit requirements strengthens the authenticity of information disclosure, especially the upgrade of audit requirements for high-risk and complex products, which is beneficial to preventing the risk of financial fraud; the special disclosure of related-party transactions is conducive to preventing the transfer of interests and protecting the rights and interests of investors.
(4) Standardization and improvement of interim reports and liquidation reports
Article 18 of the Association’s Information Disclosure Measures lists fourteen major matters and requires information disclosure obligors to disclose in a timely manner as stipulated in the fund contract. However, the disclosure time limit is not specified, and the Association’s Information Disclosure Measures provide relatively brief provisions on information disclosure requirements during the fund liquidation stage.
Chapter 4 of the new letter disclosure regulations, "Interim Reports and Liquidation Reports", improves the relevant requirements:
First, clarify the disclosure time limit for temporary reports on major events, that is, disclose them to investors within 5 working days from the date of the major event;
The second is to refine the scope of major events, adding new matters such as "the convening and resolution of meetings such as fund share holders' meetings", "changes in fund managers and valuation methods", "major adverse situations in major investment targets", "other matters that the private equity fund manager believes have or may have a significant impact on the rights and interests of investors", etc., to provide more comprehensive coverage, and highlight It clarifies the identification, judgment and duty of care of private equity fund managers on major matters that should be disclosed; and refines the scope of disclosure of major matters such as major related transactions. For major related transactions, the information disclosure obligor needs to disclose the transaction amount, counterparty, transaction price, pricing basis, decision-making procedures, etc.;
The third is to clarify the custodian’s disclosure obligations. If the custodian discovers that the fund and its manager have a situation that has or may have a significant negative impact on the rights and interests of investors, it should prompt it to perform its disclosure obligations; if it discovers that the manager is suspected of embezzling, misappropriating fund property or losing contact, it should report to the association and relevant regulatory authorities in a timely manner;
The fourth is to strengthen the disclosure requirements during the liquidation stage, making it clear that managers must promptly disclose liquidation announcements, liquidation reports and related major matters, and explain to investors if liquidation is postponed.
Practical impact: The clarification of the time limit for the disclosure of interim reports enhances the operability of the rules and prevents disclosure obligors from delaying disclosure; the refinement of the scope of major matters reduces the "fuzzy zone" and facilitates disclosure obligors to judge whether disclosure is required; the strengthening of the custodian's prompting and reporting obligations further consolidates the custodian's responsibilities; the disclosure regulations in the liquidation stage fill the previous regulatory gaps and protect investors' right to know during the fund liquidation stage.
(5) Strict management of information disclosure matters
Articles 19 to 21 of the Association’s Information Disclosure Measures provide for principle provisions on the information disclosure management system and data retention, requiring the obligor to establish an information disclosure management system and designate a dedicated person to be responsible. The retention period for information disclosure-related materials is no less than 10 years from the date of termination of fund liquidation.
Chapter 5 of the New Regulations on Information Disclosure, "Management of Information Disclosure Matters," further tightens relevant requirements: First, it is clarified that administrators and custodians should designate specialized departments and senior managers to be responsible for information disclosure matters, rather than just "special persons", which improves the level of information disclosure management within the information disclosure obligor; second, it refines the necessary matters of the information disclosure management system, adding new The "Working Mechanism for Investor Consultation" has strengthened the protection of investors' rights and interests; third, there are new requirements for the establishment of an undisclosed information management system, clarifying that relevant institutions and their employees are not allowed to leak undisclosed information, and are not allowed to use the information to engage in securities and futures transactions; fourth, the data retention period is extended to no less than 20 years from the date of completion of fund liquidation.
Practical impact: Specialized departments and senior managers are responsible for information disclosure matters, which is conducive to improving the standardization and professionalism of information disclosure work; the establishment of an undisclosed information management system is conducive to preventing insider trading, interest transfer and other irregularities; the extension of the data retention period facilitates follow-up verification by self-regulatory organizations and regulatory authorities, and also provides evidence for investors’ rights protection.
(6) Strengthening and refining of legal responsibilities
As the association's self-regulatory rules, the Association's Information Disclosure Measures can only stipulate corresponding disciplinary measures for information disclosure obligors who violate information disclosure obligations, and do not specify disciplinary provisions for custodians, sales agencies and other entities.
Chapter 6 "Supervision, Management and Legal Responsibilities" of the New Information Disclosure Regulations has greatly strengthened accountability and clarified the administrative supervision and administrative penalty powers of the China Securities Regulatory Commission and its dispatched agencies, specifically including:
First, clarify the applicable circumstances of administrative supervision measures. Measures such as ordering corrections, supervisory interviews, and issuance of warning letters can be taken against illegal entities, covering managers, custodians, sales agencies and other private equity fund service agencies, as well as employees of the aforementioned agencies, and even the managers’ shareholders, partners, and actual controllers;
The second is to clarify the applicable circumstances of administrative penalties. Those who violate core information disclosure requirements can be punished in accordance with the relevant provisions of the "Regulations on the Supervision and Administration of Private Equity Investment Funds". For specific violations (such as failure to establish an information disclosure management system, leaking undisclosed information, etc.), warnings, notifications of criticism, and fines can be given. If it involves financial security and has harmful consequences, the penalties will be increased;
The third is to clarify the scope of responsible entities, including not only private equity institutions, but also directly responsible managers and other directly responsible personnel, to achieve "equal emphasis on institutional and personal responsibilities."
Practical impact: The strengthening of legal liability has greatly increased the violation costs of information disclosure obligors, forcing relevant entities to strictly abide by the disclosure rules; the clarification of personal responsibilities avoids the situation of "organizational violations and individual exemptions" and enhances the compliance awareness of relevant personnel; the coordination of administrative supervision, punishment and self-discipline has formed a "progressive" accountability system, improving the deterrence of supervision.
3. Compliance suggestions during the transition period
The new information disclosure regulations will be implemented from September 1, 2026. It is recommended that private equity fund managers, custodians, sales agencies and other relevant entities make preparations for the transition to ensure continued compliance operations. Specific suggestions are as follows:
Comprehensively sort out the entities responsible for disclosure obligations and clarify the division of responsibilities. Private equity fund managers, custodians, and sales agencies need to refer to the new disclosure regulations to clarify their own disclosure obligations. In particular, the shareholders and actual controllers of sales agencies and managers need to establish corresponding cooperation mechanisms and management systems as soon as possible to avoid violations due to unclear obligations. It is recommended that managers, custodians, and sales agencies sign a supplementary agreement on the information disclosure of existing funds, as appropriate, to clarify their respective rights and obligations related to disclosure, ensure timely and accurate information transmission, and prevent tampering with information. Revise the fund contract and related documents and improve the disclosure clauses. It is recommended that managers take into account the requirements of the new information disclosure regulations and revise fund contracts and other documents to avoid contract stipulations that are lower than statutory requirements. For different types of funds, the disclosure content of regular reports and temporary reports must be refined and audit requirements must be clarified in accordance with the classification requirements of the new information disclosure regulations. Improve the information disclosure management system and improve management levels. Managers and custodians must, in accordance with the requirements of the new disclosure regulations, establish and improve information disclosure management systems, designate specialized departments and senior managers to be responsible for disclosure work, improve work processes and internal control mechanisms; establish an undisclosed information management system, strengthen the control of undisclosed information, prevent leak risks, and standardize data preservation. Strengthen awareness of penetration disclosure and implement relevant obligations. When managers carry out nested investments or cross-sector investments, they need to communicate with the investee in advance to clarify the cooperation obligations for penetration disclosure, ensure that the investment path and investment assets after penetration can be disclosed in accordance with the requirements of the new disclosure regulations, and avoid violations caused by the non-cooperation of the investee. Strengthen compliance training and enhance the compliance awareness of all employees. Relevant entities need to organize employees to carry out special training on the new information disclosure regulations, focusing on learning the core provisions, violation responsibilities and practical operation requirements. In particular, managers’ senior managers, persons in charge of information disclosure, and employees of sales agencies must accurately grasp the changes in the new information disclosure regulations to avoid violations due to misunderstandings; at the same time, strengthen compliance publicity for shareholders, partners, and actual controllers to ensure that they fulfill their cooperation obligations. Make a good connection between the old and new rules and ensure a smooth transition. Before the new rules on trust disclosure come into effect on September 1, 2026, relevant entities need to conduct self-examination and self-correction according to the requirements of the new rules on trust disclosure, and promptly rectify deficiencies in existing trust disclosure work; for newly established funds, it is recommended to formulate trust disclosure plans directly in accordance with the requirements of the new rules on trust disclosure; for existing funds, they need to be gradually adjusted during the transition period to ensure full compliance with the regulations after the implementation of the new rules on trust disclosure. Conclusion
The introduction of new regulations on credit disclosure is an important symbol of the continuous improvement of the regulatory system of the private equity fund industry. Its core significance is to realize the transformation of credit disclosure supervision from "self-discipline-led" to "administrative supervision and self-discipline coordination". By refining rules, strengthening responsibilities, and improving deterrence, information disclosure behaviors will be further standardized, the legitimate rights and interests of investors will be protected, and industry risks will be prevented.
Compared with the association's letter disclosure measures, the new letter disclosure regulations have made major adjustments in terms of subject scope, disclosure requirements, affairs management, legal responsibilities, etc., which are more in line with the current development reality of the private equity fund industry and are more regulatory rigid. For private equity fund managers, custodians, sales agencies and related entities, the new information disclosure regulations are not only compliance requirements, but also guidelines for industry development. Only by strictly complying with relevant regulations, improving the compliance system, and standardizing information disclosure behaviors can we achieve our own sustainable development.
As a professional lawyer for private equity funds, we will continue to pay attention to the implementation of the new information disclosure regulations, and provide legal services such as compliance consulting, system improvement, and risk investigation to relevant entities based on practical cases, so as to help the industry standardize and develop healthily. At the same time, it is also expected that the regulatory authorities will further refine relevant operational guidelines based on industry feedback during the implementation of the new information disclosure regulations to ensure that the rules are effective and promote the private equity fund industry to a higher-quality development stage.
Lawyer profile
Lawyer Yang Chunbao
First-class lawyer (senior professional title)
Senior partner of Dacheng (Shanghai) Law Firm, director of the Capital Market Department, director of the State-owned Assets Fund Research Center, professional leader of private equity and investment funds in Dacheng China, and member of Shanghai’s foreign-related legal talent pool. Bachelor of Laws from Fudan University (1992), Master of Laws from University of Technology Sydney (2001), Master of Laws from East China University of Political Science and Law (2001).
Lawyer Yang has been practicing law for 30 years and has long been engaged in private equity funds, investment and financing, M&A and restructuring legal services, covering large finance, large health, real estate and infrastructure, TMT, exhibition industry, manufacturing and other industries. Since 2004, he has been selected into The Legal 500's "Private Equity Funds" and "Company and Business" lists many times, and has been specially recommended or commented by Asia Law Profiles many times. Since 2016, he has been continuously selected as one of the "100 Outstanding Lawyers in Chinese Business" by China Business Law Journal, an internationally renowned legal media, and won the title of "China's Corporate Law Expert of the Year" in Leaders in Law - 2021 Global Awards; he has been continuously included in the recommendation list of "Excellent Lawyers & Law Firms Recommended by Well-known Corporate Law Firms in China". Qualified as an independent director of listed companies, he is a part-time professor at the Law School of East China University of Science and Technology, a practical tutor at the Fudan University Law School, a part-time graduate tutor at the East China University of Political Science and Law, a lecturer at the private equity CEO class at Shanghai Jiao Tong University, and a lecturer at the Shanghai Municipal Commerce Commission's Transnational Business Talent Training Class. Published 16 monographs including "Private Equity Investment Fund Risk Prevention and Control Operational Practice", "Enterprise Whole-Process Legal Risk Prevention and Control Practical Operation and Case Analysis", "Winning Capital 2: A Complete Operational Guide to the Company's Investment and Financing Model Process". Attorney Yang’s practice areas include: companies, investment M&A and private equity funds, capital markets, TMT, real estate and construction projects, as well as dispute resolution in the above fields.
Lawyer profile
Lawyer Sun Ai
Partner of Dacheng (Shanghai) Law Firm
Before practicing law, Mr. Sun served as the president or executive assistant to the vice president of global, Asia-Pacific or China regions in Fortune 500 companies such as Watts, Ingersoll Rand and Alcatel-Lucent in the United States. He accumulated rich experience in corporate operation management and has excellent bilingual communication and coordination skills in Chinese and English. Attorney Sun published "Private Equity Investment Fund Risk Prevention and Control Operational Practice" and published dozens of articles in the fields of mergers and acquisitions, funds, and e-commerce. Attorney Sun’s areas of expertise are: private equity investment, corporate mergers and acquisitions, e-commerce and labor law matters.
Lawyer profile
Lawyer Li Jiaxin
Lawyer at Dacheng (Shanghai) Law Firm
Lawyer Li graduated from Fudan University Law School and specializes in the fields of private equity funds, investment, financing, mergers and acquisitions, and corporate legal services. He has provided legal services such as legal due diligence and review of transaction documents for multiple parent funds in selecting fund managers and investment fund projects, as well as fund investment target company projects. He has also provided legal services related to fund raising, investment management, exit, and risk control for many private equity fund managers.
More private equity articles
Legal Bridge PE Guide ("Compilation of Private Equity Fund Regulations and Supervisory Documents") (please visit the Legal Bridge website)
Private Equity Lawyer Practice Album (click to view)
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12. Practical analysis of the legal characterization and exercise period of gambling repurchase rights
11. Case analysis of the impact of the COVID-19 epidemic on the performance of the "Vaming Agreement" and countermeasures
10. Yang Chunbao: Two dilemmas in targeted capital reduction after losing bets
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8. Case analysis of the exercise period of the right to repurchase under the gambling clause
7. The management rights trap of gambling clauses
6. See the effectiveness of the "Letter of Commitment" for private equity fund share repurchases from a case
5. Case analysis of the exercise period of the right to repurchase under the gambling clause
4. After the "Nine People", how should investors bet?
3. How should entrepreneurial companies cautiously face the risk of gambling failure caused by the epidemic?
2. Empirical analysis of a gambling case
1. Can investors bet against target companies? ——Comparative analysis of the company’s repurchase rights and shareholders’ repurchase request rights
Interpretation of regulatory policies
18. Read all the regulatory regulations and policies of the private equity fund industry in 2024 in one article
17. Read the 2023 regulatory regulations and policies of the private equity fund industry in one article
16. Eight Questions and Answers on the New Regulations on the Management of Fund Practitioners
15. Seven questions and answers on changing managers of private equity funds
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13. How many mothers-in-law do private equity funds have?
12. An article-by-article interpretation of the new regulations on registration and filing of private equity funds with the basis - General Provisions and Supplementary Provisions
11. An article-by-article interpretation of the new regulations on registration and filing of private equity funds with the basis for Part 2 - Manager Registration Chapter
10. An article-by-article interpretation of the new regulations on registration and filing of private equity funds with the basis - Part 3 - Fund Filing Chapter
9. An article-by-article interpretation of the new regulations on registration and filing of private equity funds with the basis for the fourth part - information changes and submissions
8. An article-by-article interpretation of the new regulations on registration and filing of private equity funds with the basis - Part 5 - Self-discipline management
7. Summary of regulatory policies for the private equity fund industry in 2022
6. Read the 2021 regulatory policies of the private equity fund industry in one article
5. Summary of regulatory policies for the private equity fund industry in 2020
4. Brief analysis of the main impact of new asset management regulations on PE/VC and countermeasures
3. Brief discussion on market access of foreign investment fund management companies
2. Market Entry of Foreign-invested Fund Management Company
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Analysis of judicial precedents
6. 28 typical cases in the private equity fund industry in 2024
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3. 28 typical judicial cases in the private equity fund industry in 2022
2. 27 typical judicial cases in the private equity fund industry in 2021
1. 12 typical judicial cases in the private equity fund industry in 2020
Private equity fund risk control
13. Case analysis of private equity fund managers’ compensation liability for the entire cycle of investment, management and withdrawal
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11. Case analysis on the diligence obligations of private equity fund managers in the post-investment management stage
10. Case analysis on the obligations of private equity fund managers and diligence obligations during the fund investment stage
9. Case analysis of the compensation liability of private equity fund managers in the event of delayed fund liquidation
8. Case analysis on the key points of suitability obligations of private equity fund investors
7. Let’s talk about private equity fund custody through the collapse of Silicon Valley Bank.
6. How to prepare the private equity investment fund registration document - "Prospectus"
5. Take the H asset management contract dispute as an example to discuss the risk prevention and control of private equity funds.
4. Key points for formulating risk control systems for private equity fund managers
3. Ten major risk control systems for private equity funds
2. Ten major risk control clauses for private equity investment
1. Lawyer due diligence in equity investment
Equity Fund Contract Terms
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1. Looking at the “complete agreement terms” of an equity investment agreement from an arbitration case
Private equity fund dispute resolution lawyer practice album (click to view)
Venture Capital Fund
5. Discuss the support policies for venture capital funds based on the private equity approach draft.
4. New rules! Venture capital funds and private equity funds have relaxed restrictions on reducing their shareholdings in listed companies.
3. Brief description of support policies for venture capital funds
2. An innovation-driven demonstration zone was born, venture capital funds come and see!
1. The mass entrepreneurship and innovation debt pilot will benefit private equity and entrepreneurial funds
Insurance private equity funds, industrial investment funds, S funds
7. A brief analysis of the regulatory differences between insurance private equity funds and non-insurance private equity funds
6. How to use S Fund in Shanghai? ——Introduction to Shanghai S Fund Trading Platform Business Guide
5. Brief introduction to the supervision of government-invested industry investment funds
4. Key points of legal due diligence for private equity investments with insurance funds - target funds
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2. Key points of legal due diligence for private equity investment with insurance funds—insurance institutions
1. Use industrial guidance funds to carry out mixed reform
Fund/GP/investor exit
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6. A brief analysis of the LP exit method of partnership private equity investment funds
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4. See the effectiveness of the "Letter of Commitment" for private equity fund share repurchases from a case
3. Case analysis on disputes over the withdrawal of government-guided funds
2. A brief discussion on the removal of general partners of partnership private equity funds from a case law
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