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ARTICLE · 26 JANUARY 2017

Client Briefing: 2017 - More WFOE PFMs To Come

Our understanding is that, at the least, the Illustrative Guidance does not expressly prohibit a WFOE PFM from engaging in QDLP business and private fund management business at the same time.

ChinaCorporate/Commercial Law

In line with our expectation, the first foreign-owned private securities investment fund manager ("WFOE PFM") - FIL Investment Management (Shanghai) Company Limited, a wholly foreign-owned enterprise ("WFOE") of Fidelity, obtained the registration at the beginning of 2017, six months after the WFOE PFM policy was announced in June 30, 2016. On January 4, 2017, the Asset Management Association of China ("AMAC") announced the registration of the first WFOE PFM.  Meanwhile, the AMAC published the Illustrative Guidance for the Registration and Filling of WFOE and Joint Venture Private Securities Investment Fund Managers ("Illustrative Guidance") on its website. The Illustrative Guidance provides guidance through illustration on the registration and filing related matters of WFOE PFM, and sets out detailed requirements for the legal opinion on the registration of a WFOE PFM.

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