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加中金融

基金投顾改革 Fund Investment Advisory Reform
今年 4 月，证监会发布《证券基金投资咨询业务管理办法 In April this year, the CSRC published the Administrative Measures
（征求意见稿）》，目前仍在征求意见阶段。 on Securities Funds Investment Advisory Business (Draft for
Comment), which is currently soliciting opinions from the public.
基金投顾改革的主旨在于，在销售层面，要站在客户的角 The purpose of the fund investment advisory reformis located at the
度，做买方投顾而非卖方销售。卖方销售的重心在于服务 sales level, wherein we should share the same perspective as the buyer,
卖方（基金公司），为基金产品做分销，并从中获得佣金； acting as their investment consultant rather than a sales representative
而买方投顾的重点在于为买方（基金投资者）提供配置建 for the seller. The main focus of a sales approach is to serve the seller
议，收取顾问费用。 (fund companies) by distributing their fund products and receiving
commission in return. Conversely, the focus of investment consulting
相较传统模式，买方投顾机制有利于引导居民合理配置基 is to provide the buyer (fund investors) with advice on how to allocate
金产品，避免“基金赚钱，基民亏钱”的现象屡屡发生， their assets, charging them consultancy fees for this service.
一方面提升投资者的“获得感”，另一方面使得基金管理 Compared with the traditional method, investment consulting
人免受短期波动的干扰，专心投资做好长期业绩，以便形 mechanisms help buyers distribute their capital into the most
reasonable fund products available, working to avoid the situation
成良性循环。那些业绩优秀、风格稳定、特征鲜明的主动 where the fund makes money, but the investors are losing money. On
管理人将获得更多青睐。 one side, we should be improving investors’ sense of fulfillment from
investing. On the other side, we should be safeguarding fund managers
但是，基金投顾改革需要时间去培育，不会一蹴而就。据 against interference from short-term fluctuations, and focusing on
统计，中国仅约 6%的基民在购买基金前会接受专业投顾的 making investments that perform well in the long term. By succeeding
指导，而在美国，这一比率大约是 50%。这其中，专业投 on both of these fronts, we can form a self-sustaining cycle. The active
managers who prove themselves to have outstanding performance, a
资顾问的培养是一个方面，投资者对专业服务付费意识的 consistent investment style and distinctive characteristics will be more
培养是另一个方面。 widely favored by both investors and fund companies.

推进基金投顾业务，除了培养专业化人才，利用科技手段 However, there is still a long way to go in reforming fund investment
也非常重要。最近几年，智能投顾在海内外都迅速发展。 advisory system, it is certainly not going to happen overnight. Statistics
indicate that only about 6% of Chinese fund investors will receive
去年 6 月，蚂蚁金服与 Vanguard 集团合资成立先锋领航投 professional guidance before purchasing funds, while in the United
顾，二者分别持股 51%和 49%。今年 4 月，二者合作的基金 States, this figure stands at nearly 50%. This can be attributed to two
投顾服务“帮你投”在支付宝上线，目前已获得 35 万的 reasons: the training of professional investment consultants, and the
财富号关注人数。 investors' awareness of how paying for professional services can
benefit their investments.
与国内现存的投顾服务相比，“帮你投”依托先锋集团的 In addition to training professional consultants, it is vital that we take
专业投资能力与蚂蚁金服强大的互联网基因，特点是“快 advantage of technology as a way of promoting the fund investment
诊断”“低费率”及“低门槛”。打开小程序，系统即可 consulting business. In recent years, intelligent investment consulting
一键诊断出用户的风险偏好，比如“动态进攻”，对应年 has developed rapidly both in China and abroad. In June last year, Ant
Financial Services Group and Vanguard Group jointly set up Xianfeng
化 9%的投资目标。然后，匹配策略组合，股票型基金 70%， Linghang Tougu (Shanghai) Investment Consultancy Company, 49%
债券型基金 28%，货币型基金 2%。据了解，诊断的依据是 of which is owned by Vanguard and 51% by Ant Financial. In April
用户在支付宝上的消费行为和理财习惯。投资门槛只有 this year, the “Help You Invest” service was launched by Alipay, and
800 元，远远低于国外的高门槛服务。投顾费用按年化总 has already attracted 350,000 followers.
资产的 0.5%收取，体现了普惠金融的定位。 Compared with the existing investment advisory services in China,
“Help You Invest” relies on Vanguard Group’s professional
但是，对于首次接触蚂蚁金服的投资者，或进行多平台理 investment capabilities and Ant Financial’s strong background in
财的投资者而言，一分钟诊断的准确性有待商榷。此外， Internet services to form such features as “fast judgement,” “low rate”
组合中的股票型基金仅仅涵盖指数基金（且以宽基指数为 and “low threshold” investments. When users open the mini program,
with one click the system can make a judgement for on their “risk
主，暂未涉及行业主题指数），与近几年中国资本市场结 appetite,” such as “dynamic attack,” corresponding to an annualized
构化的投资机会之间存在匹配不足的问题。 investment objective of 9%. Then, the program matches fund
portfolios, 70% for equity funds, 28% for bond funds and 2% for
money market funds. According to our understanding, the judgement
is based on user's consumption behavior and financial habits on Alipay.
The minimum required investment is RMB 800, far lower than the high
threshold for such services in foreign countries. The user will be
charged a 0.5% annual fee on assets under management, which reflects
the move towards inclusive financing.

However, the accuracy of the one-minute judgement is questionable
for investors who are new to Ant Financial, or for investors who
manage assets across multiple platforms. In addition, the equity funds
in the portfolio only cover index funds (mainly broad-based indexes;
sector-based indexes are not yet supported), which is not sufficiently
matched with the structured investment opportunities of China's capital
market in recent years.

CCFA JOURNAL OF FINANCE AUGUST 2020 Page 35 第35页