Pi Haizhou: The Qualified Investor System Must Eliminate 200 People

At the executive meeting of the State Council, chaired by Premier Li Keqiang in November 19th this year, the State Council first put forward the need to "carry out the pilot scheme for raising public interest in equity financing" and put it in the ten measures to alleviate the financing difficulties and financing of small and medium enterprises. This is undoubtedly an affirmation and support for the public shareholding fund raising, and it will also play a driving role in the prompt issuance of the public shareholding supervision method.

The SFC has done a lot of preparations for the drafting and improvement of the public ownership supervision. At the news conference held by the SFC in March 28th this year, spokesman Zhang Xiaojun said for the first time that the SFC is conducting research on the issue of equity financing, and will give timely guidance to prevent financial risks. Subsequently, Xiao Gang, chairman of the securities and Futures Commission, went to the public finance platform such as net credit and angel exchange in June 12th this year to conduct research. At the same time, the SFC's relevant departments and the Securities Industry Association convened a number of well-known domestic equity fund raising founders in Beijing to hold a seminar on equity financing. Now, in the face of the directive spirit of the State Council that "carry out the pilot scheme for raising equity financing," the China Securities Regulatory Commission and the China Securities Association also convened more than ten shareholding financing platforms nationwide to hold a forum on equity financing and financing intermediaries in Beijing in November 26th.

According to the information conveyed by this symposium, the Securities Industry Association's filing system will be relatively loose. Basically, the platform for attending the forum can be put on record. As for the threshold setting for qualified investors, there is still controversy over regulators and shareholding platforms. It is reported that in June this year, the securities and Futures Commission disclosed the idea of setting investors' threshold. The SFC intends to divide the investors into two stalls, one is a general investor, the investment amount for a single project can not exceed 15 thousand yuan or 20 thousand yuan, and the other is qualified investors, that is, investors who have the ability to invest more than 500 thousand yuan. People in the platform believe that such a threshold setting will limit the amount of investment of ordinary investors too small, and the platform is difficult to accept.

From a regulatory point of view, it is necessary to strictly enforce the qualified investor system. This is a need to protect the interests of investors, which is conducive to controlling the risk of investors in a certain range. And for the salaried class, 15 thousand yuan or 20 thousand yuan is not a small number that can be ignored. It may even be a year's savings for a wage earner. Therefore, the setting of this ceiling is not only necessary, it can not only be further improved, but also should be reduced, within 10 thousand yuan, reflecting the characteristics of "small scale" financing of the shareholding public financing platform, and at the same time, it will further reduce the risk of investors.

However, it is also difficult to accept the threshold of investors in the platform. Because the investment limit of a single investor is too low, this is not conducive to the platform side's financing function of its platform. In particular, it can not meet the financing needs of the financiers. If the financing side needs to raise 10 million yuan, according to the maximum limit of no more than 200 people, and the maximum amount of 20 thousand yuan per investor should be invested, the maximum amount of financing can only reach 4 million yuan, which is far from meeting the needs of project financing. It is also for this reason that the platform side, even the financiers, is very normal about the Commission's strict implementation of the qualified investor system.

This is strictly enforced. Accredited Investor On the issue of system, the regulatory authorities and the platform side (including the financiers) are both fair and reasonable. How to solve this problem so that the two sides can achieve unification? It should be said that this is a very easy solution. In fact, the key to the problem is not on the level of strict implementation of the qualified investor system itself, but on the issue of the maximum limit of 200 persons in non-public issuance. Because equity financing is the nature of non-public offering, and according to the provisions of the current securities law, public offering The issuing objects shall not exceed 200 persons, otherwise, they will constitute illegal securities issuance activities. Therefore, the limitation of the 200 party is the key to the problem. It is the restriction of the 200 party that inhibits the financing function of the platform side. Without this restriction, even if the upper limit of investment per investor is only 10 thousand yuan, as long as 1000 people participate in the subscription, they can also complete the financing plan of 10 million yuan.

It can be seen that it is the 200 person. limit It directly affects the development of platform financing function, and even objectively increases the investment risk of investors to individual projects. And directly led to a disagreement between the regulators and the platform side in the strict implementation of the qualified investor system. Therefore, in order to control the investment risk of investors and strictly enforce the qualified investor system, the red line restrictions of the 200 party must be abolished. Fortunately, the securities law is currently being revised, and the issue of eliminating the red line restrictions of the 200 party can be submitted directly to the revision of the securities law. After all, the setting of the red line has no reason, nor does it conform to the spirit of the State Council's "launching a pilot of equity financing and raising public funds" to ease the financing difficulties and financing problems of small and micro enterprises.