The first batch of 18 active ETFs has concluded fundraising, pulling in RMB 36 billion, with 16 of them having already rapidly built positions, leaving fund managers to face the test of having their trades "copied." The intense battle for active ETF issuance has drawn to a close. From October 23 to November 4, the first batch of 18 active ETFs completed a total fundraising task of RMB 36 billion in just nine trading days. A fast issuance pace, a large number of subscribing households, and self-purchases amounting to RMB 2.7 billion formed the three major highlights of this issuance battle. At the same time, positions were built rapidly after the close of fundraising, and 16 active ETFs have already shown fluctuations in net asset value. In addition, in the face of tests such as liquidity maintenance and the "copying trades" issue brought by transparent holdings, various fund companies have offered their assessments and reflections.

Not pursuing full-position speed: balancing costs and volatility

After the issuance battle ended, position building began immediately. Judging from current fund net asset values, aside from products under Penghua Fund and CCB Fund that closed fundraising later, active ETFs under 16 companies including E Fund, China AMC, Fullgoal, Maxwealth, JPMorgan, and Ping An have all shown signs of net asset value fluctuations. Among them, several products have already posted positive returns, meaning these products seized the volatile opportunity and have successively built positions and entered the market. A person from a fund company said the company will follow regulatory guidance, combine fund contract provisions and listing arrangements, steadily and orderly advance position building, and implement portfolio allocation in stages and progressively within the trading window before listing. "Accelerating position building is not simply about pursuing the speed of reaching full position, but rather, while improving position-building efficiency, coordinating trading costs, net asset value volatility, and smooth operation after listing," said Guotai Fund. It said it will adhere to a counter-cyclical allocation approach, not blindly chase rallies or panic-sell on declines, strictly select stocks according to the standards of "industry leaders, good free cash flow, and low valuation," insist on balanced and diversified portfolios, strictly control single-industry and single-stock weights, reasonably control turnover, prohibit short-term frequent trading and concentrated large-scale position adjustments, and ensure strategy capacity covers operational needs.

Dividend active ETF

Ping An Fund manager Liu Rongjun said that positions are currently being built at a normal pace, and the product is mainly based on a dividend strategy. In the medium to long term, dividend assets have the value of a foundation position that can weather fluctuations. With risk-free yields continuing at low levels, combined with regulatory encouragement of dividends and increased allocation by long-term funds such as insurance and pension funds, high-quality low-volatility, high-dividend assets are becoming scarce resources. JPMorgan Large-Cap Growth Active Equity ETF manager Li Bo judged that A-share valuations are in a low range, and the earnings growth rate of all A-shares excluding financials in 2026 is expected to exceed double digits, making it a good window for position building, and the stock position will be steadily raised to more than 80%.

Improving the liquidity of active ETFs

Passive ETFs track fixed indices, their portfolio composition file (PCF) is relatively stable, and the arbitrage mechanism is mature; active ETFs are different, as the PCF is adjusted daily based on real holdings, the pace of position adjustments is unpredictable, pricing for arbitrageurs is more difficult, and market makers face greater quotation risk. How to maintain on-exchange liquidity and stable premiums and discounts has become a mandatory question. Fullgoal Value Preferred Quantitative Stock Selection Active ETF manager Wang Baohe said that the product he manages sets a turnover cap during daily adjustments, reducing disturbances to the deviation of the indicative optimized portfolio value (IOPV) through small, steady adjustments; at present, the holdings method is used to create the PCF, and an IOPV publishing institution is commissioned to calculate it in real time, while cooperating with mainstream market makers to provide liquidity services, maintaining relatively stable on-exchange liquidity and premiums and discounts. Guotai Fund is advancing systematically in four aspects: first, reasonably controlling turnover and prudently selecting adjustment windows; second, assessing the liquidity of underlying targets in advance, prioritizing actively traded stocks, and improving the efficiency of basket replenishment execution; third, optimizing PCF settings, dynamically adjusting parameters such as basket size and odd-lot thresholds, and relying on a dual-manager mechanism of "active investment research plus ETF operations" to reduce the impact of fractional shares; fourth, after listing, strengthening coordination with market makers, guiding them to continuously provide two-sided quotes, and when premiums and discounts deviate significantly, using the primary-market subscription and redemption channel to guide arbitrage forces back toward convergence. Li Bo also pointed out that the company cooperates with several leading market makers, places key emphasis on premium and discount maintenance, and has established full-chain system monitoring to achieve all-weather risk control.

Fund managers face the test of having trades "copied"

Active ETFs disclose holdings daily, so every move can be observed and tracked by the outside world. While active ETF managers face the test of "swimming naked," how to prevent their trades from being "copied" has become an issue of industry concern. Liu Rongjun believes that daily disclosure of the PCF is an important institutional arrangement for actively managed ETFs and will not interfere with the normal operation of the fund. "We mainly allocate to high-quality dividend assets with good liquidity and large capacity. Even if normal follow-on trading occurs, it is difficult to cause a significant impact on the fund's position adjustments; more importantly, the core competitiveness of active management is not only reflected in 'what was bought,' but also in when to buy and when to adjust, and these cannot be simply replicated through daily disclosed holdings." Dacheng Fund said that, taking the Dacheng Dividend Smart Selection Active ETF as an example, "quantitative strategy" plus "dividend style" can naturally avoid having trades "copied": quantitative strategies hold a large number of stocks and have diversified positions, and excess returns come from multiple links such as stock selection, portfolio construction, and risk management, rather than relying on the short-term performance of a few stocks; the investment value of dividend targets comes more from corporate earnings, sustained dividends, and long-term holding, so short-term following has limited impact on long-term returns. "The Fullgoal Value Preferred Quantitative Stock Selection Active ETF uses quantitative models to build its portfolio. The alpha of a quantitative portfolio comes from multi-factor, multi-model signals and dynamic position adjustment and trade execution. Public holdings are only the optimization result, and it is difficult to reverse-engineer the original signals and weights; at the same time, holdings are diversified and single-stock exposure is low, so complete replication would entail relatively high trading costs and tracking error, and the value of replication would also decline as signals decay," said Wang Baohe. Tianhong Balanced Quantitative Stock Selection Active ETF manager Lin Xinlong believes that to solve this dilemma, one must either adhere to long-term investing and value investing and profit from long-term holdings with insights beyond the market, or respond with the systematized capabilities of quantitative investment. The advantage of quantitative investment lies in the long-term effectiveness of the strategy system. Copying a single holding is meaningless, and because holdings are diversified and the position-building cycle may take only one day, there is no way to "copy the trades."