1. Bank-based fund management companies have not broken through "separate operation and separate supervision"? Strictly speaking, "mixed operation" means that a legal person institution operates two or more businesses such as banking, securities, insurance and trust at the same time. That is to say, at least there must be an intersection between organization and business. If it's just the cross of shares, it can't be regarded as "mixed operation" in the strict sense. The difference between "mixed operation" and "separate operation" lies in the different risk characteristics of these two models and the different supervision methods adopted. Compared with "separate operation", "mixed operation" will produce tangible and intangible risk transmission, and the characteristics of "suddenness and concentration" of risk outbreak are more obvious. Only by using the "capital adequacy ratio" supervision, even if all the capital calculated repeatedly is excluded, the risk cannot be completely prevented. This is because, after the intersection of institutions and businesses, the risk correlation between various assets has changed, and the dynamic characteristics are more obvious. However, if it is only cross-ownership, the dynamic characteristics of asset risk correlation will not change substantially. As long as the repeated capital calculation is eliminated, the existing prudential supervision based on "capital adequacy ratio" is still completely effective. ? Judging from the current "Pilot Measures", only banks are allowed to invest in the establishment of fund management companies, and the institutions and businesses of banks and fund management companies are strictly restricted through various firewalls. Therefore, allowing banks to set up fund management companies at this stage does not mean that China has abandoned the restriction of "separate operation" and embarked on the international trend of "mixed operation". ? Of course, we should also see that (1) after the establishment of a fund management company, the consistency of interests will be strengthened, and products and businesses with both bank characteristics and fund characteristics may be developed. You can also unify sales channels, set up comprehensive professional sales companies, and embark on a real "mixed operation." (2) Any cross-shareholding can't just stay in the "equity" cooperation, which will inevitably bring about a series of integration, and even make use of legal gaps to integrate with each other. Therefore, allowing banks to set up fund management companies cannot be regarded as "mixed operation" in itself, but it creates conditions for further "mixed operation" and moves towards the road of "gradual innovation and gradual realization of mixed operation" ? Similarly, China's financial supervision has not changed substantially, and the division of labor between supervision departments is also relatively clear. The CIRC manages various insurance institutions, insurance intermediaries and insurance markets, the CBRC manages banks and non-bank financial institutions, and the CSRC manages securities companies, fund management companies and securities markets. In other words, separate supervision is still implemented, but after strengthening the links between various financial fields, the requirements for coordinated supervision by regulatory authorities have been further strengthened. ? Second, will the bank's sales channels be weakened and the fund industry be divided? With the fund market in China gradually turning to the open market, sales ability has become an important aspect of the competitiveness of fund management companies. At present, there are three main sales channels for fund management companies. One is the bank's sales channel, mainly aimed at individual investors, the other is the fund's own sales team, mainly aimed at institutional investors, and the other is a brokerage firm, but the sales ratio is very low. From the composition of holders, individual investors become the main holders of money market funds. At the end of 2004, among the seven funds, except for 56.69% individual investors, the rest were all above 60%. In other words, banks are one of the main channels for fund sales. After allowing banks to set up fund management companies, will the sales channels of banks be weakened? On the one hand, from the experience of the United States, the relevant fee income obtained by banks through fund management companies accounts for 0.44% of the total income in 1995 and 0.82% in 1998, that is, the income contributed by fund management companies to banks is less than 1%. The shareholder income of China Fund Management Company is not very high. Last year, a fund management company's assets reached 50 billion and its income was only over 20 million. Most fund management companies operate at a loss or at a low profit. This income level will not fundamentally change the behavior of banks. In fact, banks earn considerable income through intermediary business such as fund custody and fund consignment, and the rich products they sell will help promote the development of their wealth management business, improve the product structure, and further enhance customers' dependence and loyalty on bank outlets. Therefore, banks will not give up the fund sales business easily. On the other hand, fund management companies are gradually weakening their dependence on bank sales channels, setting up their own professional fund sales companies and paying more attention to cooperation with brokers. However, the cultivation of these channels will take some time and the healthy growth of the stock market. As the main channel of fund sales, banks will not change in the short term. ? The influence of bank-based fund management companies on the fund market lies in that it may change the existing market structure of the fund industry. Money market funds are less difficult to invest and the management cost is lower, which is only about one third of that of stock funds. If you want to make a profit through money market funds, you must have a large base scale. In recent two years, money market funds have developed rapidly in China. At the end of last year, there were only seven money market funds, and the fund share at the end of last year was 60.998 billion yuan, which has now reached 14. However, due to the small scale of money market funds of fund management companies, the average fund at the end of last year was less than 654.38 billion yuan, and a considerable number of money market funds have not yet reached the breakeven point. ? Compared with general funds, the biggest advantage of bank-based funds is that they rely on the credit of the state and banks, and individual investors have a high degree of trust. At the same time, they also have a lot of customer information, which can quickly realize large-scale economies of scale and achieve a virtuous circle. As a result, the fund market may be divided. Among the money market funds, bond funds and index funds with low investment difficulty, bank-based fund management companies will occupy the mainstream, while in the types of funds that need active management, general fund management companies will occupy the dominant position. In 1970s, American commercial banks began to engage in the initiation, management and entrustment of open-end funds. 199 1 year, there are about 1 100 fund companies supervised by banks, and the funds managed account for 37% of all funds. ? Third, the firewall can't completely avoid the transfer of interests and risks between banks and funds? In order to prevent the transmission of benefits and risks, the Pilot Measures stipulates strict firewall measures, including "separation of legal persons, separation of personnel, separation of funds and separation of information". , but also regulate the related transactions generated by resource integration. However, these measures still cannot completely avoid the transfer of benefits and risks. Specifically, the following factors will weaken the role of the firewall: (1) The natural extension of bank credit. The biggest advantage of bank-based funds lies in the background of bank shareholders. Even if the fund management company set up by the bank does not publicize the bank background in product promotion and does not compare the fund with the bank deposit, investors will naturally link the two, thus bringing the bank credit part into fund sales. If there is no mandatory requirement for funds to clarify the relationship with banks when selling products, this potential impact will exist more or less. This happened in the process of dealing with the Delong incident. ? (2) Convenient arrangements such as liquidity financing. At present, the main problems faced by funds in China, especially money market funds, are sales channels, liquidity problems caused by centralized redemption and supply constraints in money market and bond market. Banks' smooth sales channels, rich customer resources, strong financial strength and long-term experience and accumulation in the bond market and capital market have natural advantages in these aspects. Even in full compliance with existing laws, there is a huge space for resource integration between banks and fund management companies. ? (3) Information exchange is uncontrollable. In addition to customer information, pilot banks are often custodian banks of other funds, so banks have complete control over the asset portfolios and transactions of other funds. Although it is stipulated that "customer information shall not be provided to the other party in violation of state regulations", the "state regulations" are vague. In addition, the exchange of information is not necessarily in written form, so it is difficult to obtain evidence. ? 4. The establishment of fund management companies by banks has created conditions for the adjustment of financing structure? Fund management company is one of the intermediaries in the direct financing system, and its development helps to improve the efficiency of the direct financing market and the depth and breadth of the market. However, the exertion of these functions of fund management companies depends on the development of the direct financing market itself. Whether allowing banks to set up fund management companies can change the existing financing structure in China depends on the development of direct financing forms, such as the development of the primary market of stocks, government bonds and corporate bonds. ? At present, on the one hand, the issuance of corporate bonds still adopts a strict examination and approval system, the issuance quota and interest rate are strictly limited, and the issuance scale is limited; National debt is controlled by the number of issues, and the number of issues is subject to fiscal policy and national revenue and expenditure. Under the guidance of prudent fiscal policy, the circulation gradually decreased; There is a strong demand for financing in the stock market, but the basic system is not perfect. There are many phenomena such as full circulation, low quality and nonstandard in listed companies, and their expansion potential is limited. A large number of large enterprises have to seek overseas listing. The supply of financing tools in the direct financing market is limited, and there is no opportunity for a large amount of funds to invest in value-added, that is, what is currently facing is supply constraints, not demand constraints. On the other hand, due to the high rate of non-performing loans in China's banking system, there is a certain deviation between the loan term and the deposit term, and its normal operation is highly dependent on new deposits. Last year, due to macro-control and the strict capital constraints of the CBRC, the loan issuance of commercial banks shrank, and the problems brought by the decline in the growth rate of savings deposits to banks were not serious. How much savings can banks bear when the growth rate of bank loans cannot be reduced too quickly? Under the premise that the direct financing market has not yet developed, guiding the bank savings funds to flow to the money market and the capital market will cause false prosperity in the money market and the capital secondary market. When the CPI reaches 3.9%, the demand in the money market is strong and the interest rate keeps falling. One-year central bank bills only reach 2. 1555%, even lower than one-year time deposits by 0. 1 percentage point. In 2004, although the proportion of direct financing in China increased from 14.9% to 17. 1%, the total amount of direct financing decreased by 26 1 100 million yuan. At the same time, we have also noticed that government departments have realized the importance of developing the capital market. At present, they are piloting short-term corporate financing bonds in the inter-bank market, and are actively promoting the revision of corporate bond management regulations, giving up approval and interest rate control. When the direct financing market conditions are gradually improved, allowing banks to set up fund management companies will play an important role in promoting the adjustment of financing structure. Of course, the establishment of fund management companies by banks will further break through the interest rate control, ease the extracorporeal circulation of funds, and help promote the unification of the bond market.