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Is the legal opinion on the registration of private fund managers public?
According to the Announcement on Further Standardizing the Registration of Private Equity Fund Managers issued by China Asset Management Association on February 5th, 20th17th, newly registered private equity fund managers need to submit legal opinions issued by China Law Firm through the private equity fund registration and filing system. The legal opinions put forward conclusive opinions on the application materials of the applicant's registration, industrial and commercial registration, specialized operation, shareholding structure, actual controllers, related parties and branches, operating infrastructure and conditions, risk management system and internal control system, outsourcing, legal compliance, and qualifications of senior management personnel.

Since the date of the announcement, the following four situations need to be submitted to the private equity fund manager registration legal opinions:

1. To apply for the registration of private fund managers, the legal opinions on the registration of private fund managers shall be submitted as necessary application materials through the private fund registration and filing system.

2. For the applicant institution of private equity fund manager who has submitted the application before the announcement date but has not completed the registration, it shall submit the legal opinion on the registration of private equity fund manager in accordance with the above requirements.

3. A registered private equity fund manager who has not filed a private equity fund product shall, before applying for filing a private equity fund product for the first time, issue a supplementary legal opinion on the registration of private equity fund managers in accordance with the above requirements.

IV. For registered private fund managers, China Fund Industry Association will require them to supplement the Legal Opinions on Registration of Private Fund Managers according to specific circumstances.

Where a registered private equity fund manager applies to change the controlling shareholder, actual controller, legal representative, executive partner, or other major matters prudently identified by the China Fund Industry Association, it shall submit a special legal opinion on major changes of the private equity fund manager. For the requirements of special legal opinions on major changes of private fund managers, please refer to the relevant requirements of registered legal opinions of private fund managers mentioned above.

As a professional lawyer of private equity investment, I am now drafting a template of Legal Opinions on Registration of Private Equity Fund Managers according to the requirements of the Annex to the Announcement, which can be used as a reference for private equity fund managers and law firms providing special legal services for private equity funds.

Special note: the template for registering legal opinions of private fund managers is a simple template format. In actual business operation, it is necessary to make more detailed drafting according to the specific situation of private fund managers' application for registration, on the basis of full due diligence by professional lawyers, and according to laws and regulations, so as to meet the requirements of fund industry associations and achieve the purpose of smooth registration of private fund managers.