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Countries that use the trust fund management model to manage social insurance funds are
I. Occupational annuity management mode initiated by employers or trade associations.

This is mainly a very common management method in the United States, Britain, continental Europe and other countries.

The fund has a board of directors representing the interests of the beneficiaries and has the status of an independent legal person. When the board of directors exercises the duties of trustee to manage the fund operation, it mainly entrusts professional fund management companies, trust companies, investment companies and other financial institutions to invest in the fund operation through a series of entrustment agreements; Supplemented by a certain amount of direct investment.

In this occupational annuity fund model, the ownership, management and custody supervision of fund assets are strictly separated, which makes the trustee, manager and custodian form a mechanism of mutual supervision and checks and balances, which can effectively prevent the occurrence of risks such as illegal operations by operators. The performance of fund management and operation is closely related to the development of capital market, the level of integrity of all parties, external supervision ability and legal environment.

From 1984 to 1996, the average annual real rate of return of occupational annuity plans in Britain, the United States, the Netherlands, Denmark and other countries reached 6% ~ 10%, and the operating costs were also low. The annual investment management cost of many large occupational pension plans in the United States is less than 0.2% of total assets.

Second, the direct government management model.

The central provident fund directly managed by the government belongs to this model, such as Singapore, Malaysia, India, Kenya and other countries.

The characteristic of this model is that the government sets up a special organization to directly manage the daily operation of the provident fund. Implement a management model including fund management right, management right and supervision right. For example, the Central Provident Fund Bureau under the Ministry of Labor of Singapore not only manages the daily payment of pension funds, but also manages the investment and operation of pension funds.

Starting from 1992, the Singapore government allows individuals to withdraw 80% of the funds from the provident fund account and invest in the real estate and stock markets on their own. Under the mode of direct government management, pension funds are vulnerable to government intervention and lack of competitiveness, so the return on investment of funds is relatively low. For example, in Singapore, the average annual real rate of return of pensions from 196 1 to 1995 is 1.5%.

Third, the management mode of professional pension fund management companies.

Most Latin American countries adopt this pension fund management method. This model implements the system of "one person, one account" and "one company, one fund".

Pension fund management companies undertake premium collection, personal account management, investment operation, pension payment and other work according to law. Its operation mode is similar to that of * * * fund. Fund holders have no right to vote, but they can transfer their accounts to other management companies to form a competitive situation. Therefore, the success or failure of fund operation mainly depends on the corporate governance structure and government supervision level of relevant fund management companies.

In Latin America, represented by Chile, regulators require pension fund management companies to provide minimum income guarantees, mainly to reduce the agency risks of asset managers such as lack of competitiveness, inefficiency and fraud. According to statistics, the average annual real rate of return of Chilean pension funds from 198 1 to 1999 reached 10.9%.

Compared with the above two models, professional pension fund management companies have clear responsibilities, clear processes and high transparency in the management of pension funds. The existing problems are mainly the establishment cost and management cost, especially the high marketing cost, illegal sales, excessive conversion of beneficiaries between fund management companies and so on.

To sum up, I think from the characteristics of the management and operation mode and governance structure of pension funds, the operation mode of occupational annuity is more instructive. However, the direct government management and professional pension fund management companies are not suitable for China's current national conditions.

Under the circumstances that China's financial system is not perfect, the capital market and intermediary institutions are not developed, the self-discipline mechanism is not yet formed, and relevant laws and regulations are not perfect, it is necessary to adopt strict and limited supervision over the investment and operation of social security funds.

At present, an important development trend of pension fund management is that more and more external fund managers are used to manage pension funds, and with the development of internationalization, the proportion of assets managed by overseas fund managers is increasing. The main reason is the use of external professionals.