Legal analysis: it is also feasible for private equity funds to have no custodian. Private placement funds are managed by fund custodians. If the fund contract stipulates not to manage private equity funds, the institutional measures and dispute settlement mechanism for ensuring the property safety of private equity funds shall be clearly defined in the fund contract.

Legal basis: Article 3 of the Securities Investment Fund Law of People's Republic of China (PRC), the rights and obligations of fund managers, fund custodians and fund share holders are stipulated in the fund contract in accordance with this Law. Fund managers and fund custodians shall perform their fiduciary duties in accordance with this Law and the provisions of fund contracts. Fund share holders of funds established through public offering (hereinafter referred to as Public Offering of Fund) shall enjoy benefits and bear risks according to their fund shares, and the income distribution and risk bearing of funds established through non-public offering (hereinafter referred to as non-public offering funds) shall be stipulated in the fund contract.