Donghai Securities: Three stages of public offering reform are fully implemented, differentiated arrangements continue to optimize the industry ecosystem

The Zhitong Finance App learned that Donghai Securities released a research report stating that the three-stage public offering fee reform has officially been fully implemented, and the overall impact of the subscription rate reduction is limited under current rate discounts, but full inclusion of the redemption fee in fund assets will improve the stability of fund operation and effectively protect investors' interests. Furthermore, the reduction in sales service rates and the charging of sales service fees only for the first year by non-cargo bases will promote the development of long-term investment behavior and habits. At the same time, differentiating the final commission ratio also guides sales institutions to lean more resources towards individual investors and equity fund sales.

Donghai Securities believes that high-quality development of the public equity industry under policy regulations can be expected, providing a positive stimulus to brokerage business growth. It suggests grasping the main logical lines of mergers and acquisitions, wealth management transformation, innovative license exhibition, and ROE improvement. Individual stocks suggest focusing on allocation opportunities for large-scale brokerage firms with strong capital strength and steady business operations.

The main views of Donghai Securities are as follows:

Incident: The Securities Regulatory Commission revised and issued the “Regulations on the Administration of Sales Expenses of Publicly Raised Securities Investment Funds” on December 31, 2025, which will be implemented on January 1, 2026, marking the full implementation of the three-stage reform of public fund rates.

The content of the draft was optimized in four dimensions, and sales expenses in each area were further refined. Compared with the draft solicitation of comments issued in September 2025, the new regulations have been optimized and adjusted in multiple dimensions after fully absorbing market feedback. The core differences focus on four aspects: 1) The subscription fee classification is more detailed, and index funds are separately classified from the stock and hybrid categories in the consultation draft. The upper limit of the subscription rate is uniformly adjusted to 0.3% with bond funds, while active partial equity funds maintain 0.8%, and other hybrid funds maintain a maximum limit of 0.5%, further strengthening the concessionary orientation for index products; 2) The redemption fee rules are more flexible. The manuscript is only correct On the basis of ETFs, interbank deposit funds, and cargo-based funds exempt from fixed redemption fees, a clause was added where individual investors hold 7 days or more, and bond funds held for 30 days, which alleviated previous market concerns about weakening debt-based liquidity; 3) The scope of sales service fee exemptions is more clear, making it clear that with the exception of money market funds and other funds approved by the Securities Regulatory Commission, all types of funds no longer charge sales service fees after one year of holding them. Monetary Fund sales service fee collection rules; 4) The rectification period is more relaxed, and the adjustment period for the sales fee structure and rate level of funds already sold has been extended uniformly from 6 months (12 months with information technology system transformation requirements) in the opinion draft, reserving more time for the industry to adapt. In addition, provisions prohibiting fund managers from implementing discriminatory and exclusive sales arrangements have been added to strengthen the principle of fair sales.

For investors, investment costs have been significantly reduced, and long-term investment orientation has been strengthened. Combining the results of the first two stages of rate reform, the public fund industry has accumulated profits of more than 50 billion yuan to investors every year after the implementation of the new regulations, of which the sales process contributed about 30 billion yuan in fee cuts. Specifically: 1) The subscription rate has been drastically reduced. The subscription rate for stocks and hybrid funds is 1.2%, the subscription rate is 1.5%, the subscription rate for bond funds is 0.6%, and the subscription rate is 0.8%. The opinion paper unifies subscription and subscription rates, and reduces the upper limit of active subscription rates to 0.8%, 0.5%, and 0.3% for active equity, hybrid, and bond/index subscription rates; 2) The rule that all redemption fees are included in fund assets, completely cutting off the rules that induce sales institutions to “redeem” old and new A path of profit, and high short-term redemption fees (not within 7 days of holding The differentiated design of (less than 1.5%) and long-term free sales service fees effectively motivates investors to abandon short-term hype and practice long-term investments. While enhancing the investment experience, it also helps smooth out fluctuations in fund operation.

For fund sales agencies, although they are facing profit pressure, the industry is being forced to accelerate transformation. At the profit level, the reduction in subscription rates, the expansion of sales service fee exemptions, and the requirement that fund investment businesses must not charge customer maintenance fees have directly reduced the core revenue sources of consignment agencies. In particular, small and medium-sized sales organizations that rely on trailing commissions will face a major profit test. At the level of channel competition, the new regulations make it clear that fund managers can directly sell their own products without subscription fees and sales service fees. Coupled with the establishment of a direct sales service platform (FISP platform) for industry institutional investors, the cost advantages of direct sales channels are prominent. It is expected that some cost-sensitive institutions and individual investors will be diverted, and the market share of consignment agencies may shrink further. In the direction of transformation, the new regulations drive the transformation of sales institutions from “heavy scale, heavy traffic” to “heavy service and heavy insurance”. In the future, institutions will need to abandon simple product sales thinking and shift from “selling products” to “providing solutions” by improving professional capabilities such as asset allocation advice and investment advisory services, in order to gain a foothold in the competition. ETFs will further improve their sales competitiveness due to the advantage of exemption from redemption fees, and is expected to become a key layout area for leading sales organizations.

Looking at the industry ecology, push public funds to a new stage of high-quality development and accelerate industry differentiation and integration. For fund managers, small and medium-sized companies will face operating pressure to decline in revenue in the short term, but the new regulations force managers to focus their core efforts on improving investment management capabilities, attracting investors through performance rather than channel advantages, and strengthening the competitive logic of “performance is king” by setting a limit on the payment ratio of differentiated customer maintenance fees (encouraging the development of equity funds). At the level of the industry pattern, the core investment and research capabilities and service capabilities of small and medium-sized institutions will face greater pressure, and industry resources will be further concentrated on leading institutions to promote increased industry concentration. At the level of ecological optimization, the new regulations clearly attribute interest on fund sales and settlement funds to investors and prohibit discriminatory sales, further purify the industry environment and resolve long-standing industry problems such as “redeeming old and buying new” and “double charges.” At the same time, the three-dimensional fee reduction system formed by the rate reform has significantly enhanced the competitiveness of the public fund industry, helped guide more residents' wealth into the capital market through public funds, and laid a solid foundation for the industry to empower residents' wealth management and serve the real economy.

Investment advice: The three-stage public offering fee reform is officially fully implemented. The overall impact of the subscription rate reduction is limited under current rate discounts, but full inclusion of the redemption fee in fund assets will enhance the stability of fund operation and effectively protect investors' interests. Furthermore, the reduction in sales service rates and the charging of sales service fees only for the first year by non-cargo bases will promote the development of long-term investment behavior and habits. At the same time, differentiating the final commission ratio also guides sales institutions to lean more resources towards individual investors and equity fund sales. We believe that the high-quality development of the public offering industry under policy regulations can be expected, providing a positive stimulus for brokerage business growth. It is recommended to grasp the main logical lines of mergers and acquisitions, wealth management transformation, innovative license exhibition, and ROE improvement. Individual stock suggestions focus on allocation opportunities for large-scale brokerage firms with strong capital strength and steady business operations.

Risk warning: Large fluctuations in the equity market affect stock trading activity. Reduced investors' risk appetite is dragging down market sentiment, the downturn in the macro environment affects market fundamentals, and policy implementation falls short of expectations.