Against the backdrop of a rising stock market and regulatory efforts to channel long-term capital into equities, quantitative private funds have gained favor with insurance capital due to their relatively stable performance.

Since direct investment by insurers into private funds has not yet been explicitly approved by regulators, some insurance institutions have opted for an indirect route using the private fund MOM (Manager of Managers) model. This has directly spurred the growth of private fund MOM products. According to statistics, the number of such registrations hit a record high in 2025.

The parent fund managers for products registered over the past year were primarily securities asset management companies and futures firms. However, cross-verification with multiple securities asset management sources indicates that new registrations for private fund MOM products have been suspended. The primary reason is regulatory concern that this business could devolve into "conduit" activities in practice, straying from active management principles.

**Concerns Over Conduit Business** The market has long focused on insurance capital accessing quantitative strategies indirectly through private fund MOMs. However, this avenue has now been quietly put on hold.

"The suspension has been in effect for at least three months with no resumption in sight," stated a representative from a small-to-medium-sized securities asset manager in Shenzhen. Public information from the Asset Management Association of China shows that after a batch of private fund MOM products were registered on September 2, 2025, no further registrations have been recorded.

Discussing the reasons, several securities asset management professionals pointed to regulatory fears of the MOM business becoming a mere conduit. A representative from a small-to-medium-sized securities asset manager in North China explained that while securities firms have successively launched MOM products in recent years, primarily funded by insurance institutions, regulators are concerned the business might shift away from active management, becoming a conduit. This would contradict the current regulatory direction of "de-channeling" in the asset management industry.

Structurally, insurance capital typically invests directly in a securities firm's single-asset management plan, with a private fund acting as the investment advisor. Effectively, the insurer is purchasing a private fund strategy. Association records also show that the management type for registered private fund MOM products is mainly labeled as "advisory management."

Industry insiders explain that in this structure, the securities asset manager, as the parent fund manager, should select private fund managers through long-term tracking and research, while also setting risk control thresholds and capital allocation ratios. Operations within these thresholds are handled by the sub-advisor. However, if the parent manager completely relinquishes core investment decisions—for instance, letting the insurer decide which private funds to invest in and the allocation percentages—and merely provides the license and account, it constitutes a departure from active management.

A representative from a large insurance asset management company previously noted their reluctance to use the MOM route for quantitative investments due to high compliance costs and stricter audits, with the risk of being classified as a conduit business. "Following investment advisor instructions is largely passive execution; debating whether active management exists could take considerable audit time," they said.

**Record-High Registration Numbers** The continuous inflow of bank wealth management and insurance capital into the market in recent years has fueled rapid growth, including for MOM products. Data from the Asset Management Association of China shows a significant surge in private fund MOM registrations from 2024 to 2025.

According to statistics, 58 new private fund MOM products were registered throughout 2025, setting a historical record and more than doubling the 2023 figure of 23. In comparison, the numbers for 2020 to 2023 were only 9, 5, 3, and 17 respectively, indicating historically low registration activity for MOM products prior to the recent surge.

Discussing the reasons for the recent "registration wave," industry participants cited bank wealth management and insurance capital as the core drivers. MOM products with quantitative private funds as advisors, known for their flexible strategies and ease of risk diversification, align well with the current risk preferences and tolerance of institutional clients.

It was noted that among the newly registered private fund MOMs in 2025, nearly 60% were structured as single-asset management plans.

The naming conventions of some registered products also reveal the pathways through which medium to long-term capital enters the market via MOMs. For example, some products follow a "Manager - Insurance Company/Bank Wealth Management - Strategy" naming pattern, indicating participation from various institutions like bank wealth management divisions and life insurance companies.

**Business Outlook Remains Unclear** Securities asset management firms were the main drivers in the 2025 private fund MOM registration wave, with some individual companies performing notably.

Another representative from a small-to-medium-sized securities asset manager in North China analyzed that securities firms have certain advantages in developing MOM businesses, such as transaction transparency—allowing them to monitor sub-managers' trades, investment styles, and capabilities through their systems. They can also pre-set and monitor risk indicators, maintaining unified control over overall risk.

Statistics show that five securities companies successfully registered MOM products in 2025, accounting for 39 products collectively, or 67% of the annual total. Among them, Huaxin Securities registered 30 products alone, representing 77% of the securities firm segment. Guojin Asset Management and Ping An Securities registered 4 and 3 products respectively.

Huaxin Securities' performance did not surprise industry observers. Some insiders suggested it might be related to the company's long-standing resource accumulation in the quantitative private fund sector.

However, with the sudden halt on new registrations, some securities asset managers who had invested resources but not yet fully launched their businesses are feeling the strain. One securities asset management professional admitted that MOM business requires investment in specialized technical systems. With operations now stalled,前期投入面临压力前期 investments are under pressure.

Looking ahead, several institutions believe the suspension may be temporary. The aforementioned North China securities asset manager stated that regulators likely need time to study and clarify relevant policies, expecting a eventual reopening.

An insurance investment professional anticipated that regulators might subsequently issue clarifications or additional requirements. For instance, they might impose clearer demands on trustees, stipulating that both the securities platform and the private fund company within the MOM structure need the capability to manage insurance capital. Subsequently, managing insurance funds might require specific business qualifications or licensing. "Due to the large volume of insurance capital and its low risk appetite, it differs significantly from general market funds," they noted.