In addition, the notice clearly pointed out that those who do not meet the requirements of the relevant number of employees should complete the rectification as soon as possible within three months. After the expiration of the rectification period, the association will take further self-discipline measures against managers who still do not meet the requirements.
Regarding the Notice, we remind private placement managers to pay attention to the following matters:
What is the purpose of the rectification of the China Foundation?
China Foundation Association's Supervision and Acceptance Criteria?
After consultation with the staff of the association, the rectification targets include all private fund managers, and all surviving managers should conduct self-examination and rectification of their own employees to meet the requirements of the association.
Among the 24,600 private equity managers in China, there are more than 9,900 private equity managers with less than 5 full-time employees registered on the employee management platform!
If the number of full-time private placement managers is increased to more than five according to the requirements of the China Foundation, about 40% of private placement managers need to be rectified in the next three months.
It is not difficult to see that this move by the China Foundation will increase the compliance operating costs of private fund managers.
The purpose of the rectification of the China Foundation is to gradually "clear out/clear out" those "empty shell/small private placement managers" who cannot complete the compliance operation.
After consulting by the staff of the association, the judgment basis for supervision and acceptance after 3 months is to review the employee management platforms of private equity managers to see whether the number of "full-time employees" registered on the platforms is not less than 5.
Private placement managers can log on to their own employee management platform (/web/login.html) or inquire about the number of full-time employees of China Foundation-private placement fund managers (/amac-infodisc/res/POF/manager/managerlist.html).
? How to define "full-time employee"?
Are retired employees "full-time"?
? How to define the number "five"
For full-time employees, it refers to those who sign labor contracts with private placement managers and pay social security for them.
If the employee is older and retired, the private placement manager may not pay social security for such retired and rehired employees, but he needs to provide his retirement certificate.
Retired and rehired employees are "full-time employees".
Full-time employees, including senior managers and ordinary employees.
According to the definition of China Foundation, senior managers refer to the legal representative/managing partner (appointed representative), executive director/chairman, general manager, deputy general manager (if any) and compliance/risk control person in charge of private placement managers.
Ordinary employees refer to employees who are engaged in fundraising, investment (including transactions), risk control, operation, research, finance, administration and other positions.
How to determine the number of five employees?
In fact, anyone who has signed a labor contract with a private placement manager and paid social security is considered a formal employee; Retired employees are also regarded as full-time employees.
But part-time employees should not be included in the number of full-time employees.
For some group private equity managers or related private equity managers, if the same person concurrently holds the legal representative or other senior management positions of multiple private equity managers, they can be recognized as regular employees under the private equity managers who pay social security for them, and can only be recognized as part-time employees under other private equity managers, but not as regular employees.
The number of the above-mentioned full-time employees is greater than or equal to 5, and all of them have been entered into the employee management platform of the organization (those with fund qualifications are registered and entered, and those without fund qualifications are entered), which meets the requirements of rectification.
Do all five full-time employees need to be qualified for fund practice?
Do full-time employees who have not taken the exam need to sign up for the employment system?
About the fund qualification of all employees:
Therefore, in fact, we suggest that applicants can only have employees who are engaged in finance and administration, and all other personnel must have fund qualifications.
In addition, many private equity managers are wondering whether full-time employees who have no fund qualification or have not been admitted at all need to register and enter the employment system. Where/at which port do you operate if you need to register for entry?
We explicitly replied to the private placement manager that full-time employees who have no fund qualification or have not been admitted at all need to register for the employment system. Even if they fail the exam, they can enter the employee management platform, which is an effective figure.
On the operation path, China Foundation recently optimized and updated the employee management platform, adding the category of "Unqualified".
In the private placement manager-institution manager account, after creating a new-personal user account for full-time employees without professional qualifications, unqualified personnel can log in to their-personal user port, fill in their basic information, educational background and work experience, and then check "Without professional qualifications" in the application category of the "Professional Qualification" module. The chart is as follows:
Some suggestions written at the end.
1. Under the confirmation of the private placement manager, what are the reasons why there are less than five full-time employees registered in the employee management platform? Did you just forget to enter it?
The number of full-time employees of some managers is not less than 5, but due to ignoring the compliance operation, they forgot to register the personnel who entered the employee management platform.
In this case, it is suggested to complete the registration and entry by yourself according to the resume information of the personnel specified in the registered legal opinion, or to sort out and check the resume information of the relevant full-time employees by yourself.
As an extra reminder, it is suggested to carefully sort out and check the resume information of full-time employees, because after the new employee management platform enters and registers the resume information of employees, their resume information cannot be modified or deleted, so please be careful.
Secondly, it is suggested that private equity managers conduct self-examination, and those who actually leave their jobs but have not completed major changes in the AMB system or left their jobs can be sorted out simultaneously within a three-month period.
Thirdly, if there is a real shortage of full-time employees, it is suggested that private managers find suitable candidates as soon as possible, make up five full-time employees as soon as possible and complete the entry and registration of the employment system as soon as possible.
You can find those candidates who have passed the fund qualification examination (or equivalent to passing the fund qualification examination) and directly enter and register the employment system, or you can enter and register the employment system after completing 30 hours of training in the past two years.
Fourth, for those who have completed the registration of the employee management platform, they need to complete the annual follow-up training from the second year, don't forget.
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