Selected projects delivered with practical execution and advisory support
Shenzhen XX Private Securities Fund Management Co., Ltd.
Manager type: private securities investment fund manager. Total project cycle: 4 months. Client issue: the applicant planned to apply for private fund manager registration with AMAC. The company had ten shareholders with equal 10% stakes, so the client initially believed it had no actual controller because ownership was dispersed. Our approach: based on prior filing practice, we clarified that AMAC expects a private fund manager applicant to identify an actual controller. We built the controller analysis from governance arrangements, concerted action, decision-making influence and trace-through ownership to natural persons, state-owned enterprises or listed companies where applicable. We also explained that joint control by multiple persons may be accepted when properly supported. Conclusion: even with dispersed shareholding, a defensible actual-controller analysis can usually still be established under the applicable filing logic.
XX (Sanya) Private Fund Management Co., Ltd.
Manager type: private securities investment fund manager. Total project cycle: 3 months. Client issue: the senior management team was unclear about the route to obtaining fund practitioner qualification and assumed that incomplete exam completion meant the qualification could not be recognized. Our approach: after repeated communication with the client’s actual controller, we confirmed that the executive had already passed Subject 1 and held a CFA qualification. We then matched that background against the AMAC qualification-recognition rules and reorganized the filing materials accordingly. Conclusion: under these circumstances, the executive satisfied the conditions for qualification recognition instead of needing to delay the filing.
XX Private Securities Investment Fund Management Co., Ltd.
Manager type: private securities investment fund manager. Total project cycle: 5 months. Client issue: the applicant had two affiliates, and one affiliate’s business scope involved a conflicting business category identified by the regulator. Another affiliate also touched a potential conflict area. Our approach: we separated inactive conflict business, coordinated deregistration commitments where necessary, and disclosed the affiliates’ business status, regulatory background and the independence of the applicant in business, assets, personnel, organization and finance. We also supplemented the filing with supporting explanations and compliance evidence. Conclusion: the filing package addressed affiliate conflict concerns through a clearer isolation, disclosure and independence framework.
Shenzhen Qianhai XX Capital Management Co., Ltd.
Manager type: private equity investment fund manager. Total project cycle: 4 months. Client issue: after completing its corporate registration change, the client planned to submit a legal representative change filing to AMAC. The new executive team involved concurrent positions across related entities and one outside investment company. Our approach: we reviewed AMAC’s practical guidance on executive concurrent positions, preserved the acceptable roles within related entities and required the client to remove the incompatible external role before filing. The supporting materials were then reorganized for concurrent-position disclosure and non-compete review. Conclusion: the project moved onto a compliant material-change filing path with a clearer remediation plan.
Coordinated registration delivery across multiple Hainan entities
We supported a sequence of Hainan registration projects covering limited partnerships and limited liability entities. Typical delivery cycle: about two to three weeks per registration, depending on entity type and document readiness. Scope included entity setup coordination, filing materials, registration follow-up and milestone tracking through issuance of the final corporate records.
Name rectification for registered private fund managers
After the CSRC strengthened naming requirements for private fund businesses, several registered managers needed to complete name rectification. Our role covered policy interpretation, filing-path design and execution support across multiple approved projects completed in Shenzhen in 2021. This work focused on turning the naming requirement into an operationally manageable change project rather than a prolonged compliance risk.