中美贸易摩擦、美国大选，当然还有新冠疫情。过去一年中难以预见的危机不断出现在了亚太地区投资基金产业面前。伴随基金不断随创新及技术演化，它们对律师也产生了类似要求。在特殊的2020年中，离岸律师事务所显然迈进一步，迎向了挑战。
2020年濒临结尾时，亚太地区的经济图景似乎呈现出前所未有的萧条：某些地区动荡的社会环境、远不够理想的经济状况、余温未了的中美贸易摩擦，当然，还有那场百年一遇的疫情——投资基金领域当然也难逃一劫。“全球交易活动都被踩了刹车，融资变成难题，小型基金的经理感受尤甚。”凯瑞奥信律师事务所新加坡办事处管理合伙人Anthony McKenzie说，“ 因此，部分基金发行被叫停，部分既存基金（及其投资组合公司）面临估值困难。有些对冲基金需要谨慎管理赎回，并利用起类似赎回上限和‘侧袋账户’这样的流动性管理工具。”
McKenzie补充说，亚太地区投资基金产业正受疫情影响加速剧变。他观察到：“远程办公，很少有机会进行面对面交流、募资路演及运营尽职调查，这很大程度改变了投资经理的作业方式，律所应该留意客户预期的变化，并将应对策略纳入未来计划之中。”
Kate Hodson是奥杰律师事务所香港办公室合伙人，她说，2020年初疫情刚爆发时，大家曾一度因为担心流动性而叫停了大量项目，尤其涉及中国的交易，很多都延期了。“不过，伴随封锁程度降低，亚洲资产管理产业逐渐适应‘新常态’，交易活动再次活跃起来。” 她指出，“科技产业尤为坚韧，疫情甚至导致新机会产生：例如健康产业，以及线上购物及支付产业。”
与此同时，康德明律师事务所香港办事处合伙人龙翔德（Piers Alexander）告诉ALB，和2019年相比，他所在律所2020年服务的房地产基金相对减少，反映出疫情下对商业、消费及办公空间需求的变化，以及酒店及其他旅游住宿产业的低迷。“无法面对面开会既影响了募资，也改变了针对新基金的尽职调查。”他指出，“不过，这也意味着既存的投资者关系变得更为重要，并为重复建仓铺平了道路。基金经理还可以善用这些关系来引入新资本。”
龙翔德补充说，2020年对冲基金在亚洲的强势表现促使该领域投资者利益发生变化，2021年这些基金依旧蓄势待发，并预期看到更多新基金发行。“私募债权基金也很受欢迎，但2020年我们协助发行的新基金中，大多数仍是中国的私募股权基金。”他说。
McKenzie也在去年看到了不少亮点。“很多基金经理在2020年保持住了乐观心态，有效利用了低估值、困境资产和动荡的市场。投资于关键产业——例如金融服务、IT、教育和健康的风险投资及私募股权基金最引人注意。债权基金、困境投资基金和错位基金也势头正起。”他说。
监管提升
就算2020年的一系列事情都没有发生，基金也难以高枕无忧，因为它们不得不面对加速变化的监管图景。“我敢说，对于基金经理而言，感觉像是每年都有新的基金法规颁布。”Hodson说，“2020年私募股权基金领域发生了新变化，在开曼群岛和英属维尔京群岛（BVI）成立的基金开始成为监管对象。新立法源自欧盟及其他国际标准的制定，目的是让BVI和开曼群岛的投资基金监管体系和其他司法管辖区相关体系相兼容。”
彭德贤（Michael Padarin）是凯瑞奥信香港办事处管理合伙人，他具体解释道：“在欧盟和经合组织（OECD）的压力下，2020年，开曼群岛和BVI都针对之前不受监管的封闭式基金制定了新监管制度。开曼群岛的新制度最具代表性，过去多年来这里都被欧洲以外的资产管理经理视为预设基金的大本营，现在却要面对剧烈的监管变化。举例说明新制度的影响力：截至2020年8月初，大约有1.3万支私募基金按新规要求在开曼群岛进行了注册。”
他所在律所帮助大量客户完成了注册要求，并正帮助客户在类似估值、财产保管和审计等重点领域履行若干运营合规义务。“不出所料，不愿意在新规下承担额外费用和合规义务的客户开始向我们咨询其他不受监管的司法管辖区，我们也帮助他们寻找到了新的解决方案。”彭德贤说。
龙翔德对此表示赞同，他指出，开曼群岛2020年2月颁布的《私募基金法》是近年来“对开曼投资基金影响最大的”一部法规，因为它第一次将封闭式基金置于监管之下。“虽然新法对封闭式基金施以新监管及合规要求，我们还未看到它影响了新基金的成立数量，或者导致开曼群岛对于私募股权基金的吸引力降低。”
Hodson也做出了类似观察。“虽然新法规要求注册，我们还未看到因为躲避监管而选择其他司法管辖区的情况发生。相反的，许多落入新法适用范围的实体已经选择了在BVI和开曼群岛进行注册。”她继而补充说：“我们没看到在开曼群岛及BVI设立基金的热情度的减弱，不过大家确实在咨询不同司法管辖区对于不同载体监管要求的差异。”
彭德贤还说，2019年生效的开曼群岛《经济实质法》仍旧是客户热议和问询的话题。“开曼群岛投资基金总的来说不受该法管辖，不过，基金经理和投资组合控股公司有可能受该法管辖，我们已经就该领域架构及合规问题为不少客户提供了咨询。”
可持续方法
另外一类监管则有点让亚太地区的基金经理们措手不及，Hodson指出，这就是逐渐引入的气候变化监管。“法律框架开始支持低碳经济，这种转变预计将在中短期内对金融市场和金融产品产生较大影响。”她说。
不过，总的来说，环境、社会和公司治理话题（ESG）对基金经理正变得愈发重要。“ESG逐渐升级的影响力使得亚洲不少新基金产品都以某种方式纳入了ESG元素。”Hodson说，“我们还遇到几位基金经理，他们对于将更多ESG策略带入市场表现出兴趣。除了固定收入类产品，我们看到可持续性投资产品愈发多元化了。新产品之外，基金领域还在发生其他和ESG相关的变化，包括对于可持续金融领域人才的追捧。这种变化不仅发生在资产管理公司，还发生在银行和会计师事务所。它还催生了新的伙伴及合作关系，例如混合金融，或者非政府组织和资管经理共同开发新基金。”
受到政府和监管者的大力支持，Hodson认为ESG将成为长期趋势。“举例来说，中国香港特别行政区和新加坡都启动了咨询程序，旨在指导资产管理行业做好气候风险披露，而且两座城市还在互相较劲，都想成为亚洲绿色金融中心。”她指出，“事实上，香港证监会正提议颁布新措施，要求在港注册的基金经理都在投资和风险管理过程中考虑气候相关风险。”
龙翔德也预计在2021年，可持续发展投资将大幅增长。“在渣打银行发布的《2020年可持续投资报告》中，该机构对新加坡、中国香港、阿联酋和英国大约一千位富裕阶层和高净值投资者进行了调研，发现亚洲地区90%的受访者表示对可持续发展投资感兴趣，42%的受访者计划在未来三年中在该领域投资5-15%。对不少全球规模超大的公司而言，疫情加速并强化了将可持续发展和ESG因素纳入商业策略的重要性，即便疫情结束，这一势头也不会减弱。”他说，“法律和监管对于投资中ESG因素的关注意味着ESG也将成为亚洲投资者的关注重点，基金经理要能够应对客户预期。”
Hodson相信这也为离岸律师事务所带来了机遇。“就像商业机构一样，律所也得考虑可持续发展和坚韧度问题。”她说，“在科技和客户服务之外，我们现在也很关注研发、环境和健康。其中环境尤为重要。律所因此设立了环境管理系统，聘请了一位可持续发展主管负责该项目。举个创新的例子：奥杰在疫情期间设立了一条全新的服务线，名字叫做‘奥杰全球ESG及影响力咨询’ 业务。我们通过这条产品线提供定制化ESG及影响力设计、融合及实施方案，支持客户实现ESG目标和要求，以更好利用可持续发展投资机遇。”
闪光时刻
伴随客户在一系列挑战中不断创新进化，离岸律师事务所也不甘落后。“过去一年为我们提供了独特机遇，可以重塑离岸律师和客户的工作关系，并重新思考我们在业务领域、产业及地理位置上的布局及规模。”凯瑞奥信的McKenzie说，“深刻了解客户业务内容的律所更容易度过疫情难关，并快速响应。此外，认同‘沟通至上’的律所更具坚韧度，并能更有效地和员工及客户合作。那些善于创新、灵活度高并乐于投资于科技工具的律所会发现，疫情中它们反而积累了商誉，使客户和员工更具品牌粘性。”
奥杰的Hodson表示，考虑到2020年开年以来发生的一系列监管变化，不断触及并高效支持客户变得十分重要。“科技工具成为了提供解决方案的首要依靠。”她回忆道，“我们在年初很快展开了线上研讨会和系列讲座，并将这些产品持续了一整年。此外，奥杰的IT系统和‘久经考验’的网络平台也使我们能够及时转向远程办公和线上交易。我们当时已经使用了一段时间电子签章产品，因此能为无法手写签字的客户提供服务。幸运的是，开曼群岛自2003年修订《电子交易法例》后，已经做好了准备接受电子形式签章。”
她同时指出，离岸律师事务所间进行了许多合作，以确保用相同方式为客户分析解释BVI及开曼群岛基金领域监管的诸多变化，为该行业提供清晰、且尽可能一致的支持。“现在大家都想的是‘行业优先’，这对于去年本来就饱经挑战的客户来说十分重要。”Hodson说。
“无法面对面交流显然有许多弊端，但也带来效率上的好处。举例来说，去年我们坐在家中或办公室里，就参加了很多跨司法管辖区的线上会议。不过，网上论坛的问题在于无法社交，我们得额外花精力联络及开发客户。”
龙翔德说，康德明将继续为客户提供离岸法律协助，以实现他们的商业需求。“这一承诺不断驱使着我们在亚洲的法律服务布局。”他指出，“事实上，离岸法律服务的意义正反映出离岸司法管辖区本身的意义和作用广度，即为离岸实体提供稳定、监管质量高且具备灵活性的平台，以满足客户的商业需求。”
展望2021
展望前路，McKenzie预期亚太投资者会继续将投资资本分配到替代性渠道。“我们预期中国将继续领跑离岸交易，包括中国基金经理发行新的离岸基金、设立合资公司、寻求科创版上市、股东主导私有化交易、优先股融资，以及大型跨国并购交易。自20世纪80年代启用以来，开曼群岛和BVI结构已经并将继续在这类交易中扮演核心角色。中国的基金经理和投资人也对离岸司法管辖区的创新型基金及其他产品反响不错。”
彭德贤补充道，疫情引发的经济下行导致亚太地区陷入财务危机的公司数量加剧。“过去六个月中，向我们咨询重组和破产业务（有争议或无争议）的客户数量出现显著增长，伴随疫情引发的经济震动持续发酵，这一趋势还将持续12至24个月。”他指出，“对基金管理产业来说，这为机会型并购基金收购困境资产，或以折扣价收购既存基金中的二级份额提供了更多机遇。”
与此同时，龙翔德预期开曼群岛基金的发展将与亚洲经济的复苏保持同步。“复苏很大程度取决于各司法管辖区的抗疫能力，包括迅速展开疫苗接种的能力。亚洲某些司法管辖区表现得更为高效，面对2021年准备也更为充分。”他说，“中国近期公布的GDP 2.4%的增速为2021年全球发展竖立了标杆，针对中国的入境投资也将成为开曼群岛的关注重点。”
对Hodson来说，过去一年中被压抑的活动在2021年初就迎来爆发，她所在律所1月份非常繁忙，接到了大量新基金发行业务及其他问询。“对于2021年的业务量，我们还是保持谨慎乐观。”她说，“伴随中国进一步开放外资进入，许可外企在证券和基金管理公司中控股，以中国为核心的活动将成为另一大趋势。”
Fund Times
The U.S.-China trade war, the U.S. elections, and of course COVID-19. Last year saw unprecedented challenges for the investment fund industry in the Asia-Pacific region. But as funds adapted through innovation and technology, they expected their lawyers to do so as well, and offshore firms certainly stepped up to meet the challenges brought by a very unique year.
By the time 2020 drew to a close, it felt like the business landscape of the Asia-Pacific region had been battered like never before, with civil unrest in Hong Kong, less-than-ideal economic conditions and lingering uncertainties over the U.S.-China trade war combining with a once-in-a-century pandemic. The investment funds industry was unsurprisingly not spared. “The brakes were applied on global transactional activity and fundraising became a challenge, particularly for smaller fund managers,” says Anthony McKenzie, managing partner of offshore law firm Carey Olsen’s Singapore office. “As a result, a number of fund launches were put on hold. Several existing funds (and their portfolio companies) experienced valuation difficulties. And some hedge funds have had to carefully manage redemptions and employ liquidity management tools such as gates and side pockets.”
McKenzie adds that the Asia-Pacific investment fund industry as a whole is undergoing significant adaptation as a result of the pandemic. “Remote working, alongside fewer opportunities to interact face-to-face, go on fund-raising roadshows and to undertake operational due diligence, has led to significant changes in the way investment managers conduct their business, and law firms increasingly need to be aware of such clients’ changing expectations in order to integrate them into their strategy going forward,” he observes.
Kate Hodson, a partner at the Hong Kong office of offshore law firm Ogier, says that at the start of 2020, as the pandemic began to have its impact, there were liquidity concerns and a significant number of projects put on hold, with many China deals stalling. “However, as lockdowns eased and the asset management industry in Asia adjusted to ‘the new normal,’ activity quickly resumed,” she notes. “The tech industry, in particular, proved very resilient and there were a number of pandemic-induced opportunities such as in healthcare and those industries benefiting from changing purchasing patterns, with a huge shift to online spending.”
Meanwhile, Piers Alexander, a partner in the Hong Kong office of offshore law firm Conyers, says his firm saw fewer new real estate funds compared to 2019, reflecting the changing needs for commercial, retail and office space, as well as the down-turn in occupancy for hotel and other tourist-driven accommodation, resulting from COVID-19. “The end of face-to-face meetings affected both capital raising and manager due diligence concerning new funds,” he notes. “However, it did mean that existing investor relationships became even more important and smoothed the way for repeat funds, as well as allowing managers to leverage such relationships for new capital introductions.”
Alexander adds that the return to stronger performance of Asia hedge funds in 2020 saw renewed investor interest in this sector, placing these funds in a good position for 2021 and the prospect of increasing numbers of new launches should this performance continue. “Private credit funds also proved popular, but it was China private equity which continued to be the main-stay for the new funds we assisted on in 2020,” he says.
Likewise, McKenzie witnessed many bright spots last year. “Many fund managers were opportunistic in 2020 and took advantage of lower valuations, distressed assets and volatile markets. Venture capital and private equity funds, particularly those investing in key industries such as financial services, IT, education and healthcare were most notable. Credit funds, distressed asset funds, and dislocation funds have also been on the rise,” he says.
Ann Ng, a partner at Maples and Calder in Hong Kong, says that her firm is witnessing a maturing of the funds management industry in Asia, as well as increased innovation and dynamism. “Hedge fund managers are venturing into private investments and other illiquid assets through voluntary side pockets, co-investment arrangements or co-mingled PE funds,” she notes. “Similarly, traditional PE managers and their investors are seeking opportunities in more liquid assets on the secondary market. On the investor side, we are seeing some institutional investors investing for the first time in private equity and other alternative asset classes in the search for yield.”
REGULATIONS RAMPING UP
Even if the abovementioned events had not happened, funds would have had plenty to worry about, and many of those worries would have come from the ever-changing regulatory landscape. “I am sure that to a fund manager it feels like every year, a new fund regulation,” says Hodson. “2020 saw a new development in the private equity space with private funds domiciled in the Cayman Islands and the British Virgin Islands becoming subject to regulation. The new legislation was a result of certain EU and other international recommendations and was developed to align the BVI and Cayman Islands investment fund regulatory regime with other jurisdictions.”
Michael Padarin, Hong Kong managing partner at Carey Olsen, elaborates. “As a result of pressure from the EU and the OECD, during 2020, both the Cayman Islands and the British Virgin Islands introduced regulatory regimes for previously unregulated close-ended fund structures. The Cayman Islands regime, in particular, represented a very significant regulatory development for a jurisdiction which for many years has been the default fund domicile of choice for ex-EU asset managers. To illustrate the magnitude of this change, approximately 13,000 private funds were registered in the Cayman Islands under the requirements of the new regime by early August 2020.”
He says that his firm assisted numerous clients in navigating the registration requirements, and is helping clients come to grips with several new operational compliance obligations, in key areas such as valuation, safekeeping of assets and audit. “Unsurprisingly, clients who do not need the added expense or compliance burden brought about under the new regimes, are enquiring about unregulated alternatives,” says Padarin. “This is particularly the case for fund-of-one structures, and co-investment vehicles, and we have found solutions for a number of clients under these circumstances.”
Alexander agrees that the introduction in the Cayman Islands of the Private Funds Act (PFA) in February last year was the single measure having the “greatest impact on Cayman investment funds” for the year, as it brought closed-ended funds within the regulatory fold for the first time. “Whilst the Act imposes new regulatory requirements and ongoing compliance on closed-ended funds, we have not seen this affecting the volume of new funds established or negatively impacting the attractiveness of Cayman as the leader for private equity funds in Asia.”
This is an observation echoed by Hodson. “Despite the new obligations of having to become registered with a regulator, we saw very little interest to move out of these jurisdictions to avoid regulation. Rather, most in-scope entities have chosen to register with the BVI and Cayman regulators,” she says.
“We haven’t seen this as detracting from the continued interest in Cayman and the BVI for fund set-up, although there is now perhaps a slight uptake in drilling into the respective regulatory treatment of different vehicles in each jurisdiction,” she adds.
Padarin also notes that, separately, the Cayman economic substance regime introduced in 2019 remains a hot topic and the subject of many client queries. “Cayman Islands investment funds are broadly exempt from the regime, however, fund managers and portfolio holding companies are potentially in scope and we have advised numerous clients on structuring and compliance in this area,” he says.
SUSTAINABLE APPROACHES
Another new type of regulation that has perhaps taken managers by surprise in the APAC region, is the gradual introduction of climate change regulation, says Hodson. “Legal frameworks have begun to reflect support for the transition to a low carbon economy and this transition is expected to have a major impact on financial markets and products in the near to medium term,” she notes.
Broadly speaking, though, the issue of Environmental, Social, and Corporate Governance (ESG) is becoming front and centre for fund managers. “The momentum around ESG has started to translate into new funds products arising in Asia which incorporate ESG in some form,” says Hodson. “We have also seen several managers indicating interest to bring more ESG strategies to the market. This reflects a diversification in the sustainable investment product bank away from fixed income. Beyond new products, we are seeing a number of things happening in the funds industry related to ESG, including a spree of hiring individuals with experience in sustainable finance. This is not just into asset management firms but also banks and accounting firms. There have also been increased opportunities for new partnerships and co-operations such as in the form of blended finance and NGOs working with asset managers on fund launches.”
Hodson sees ESG as a long-term trend as substantiated by the commitments seen at the levels of government, as well as regulators. “As an example, both Hong Kong and Singapore have started a consultation process with regards to guiding the asset management industry on climate disclosures and are competitively positioning themselves as Asia’s green financial centres,” she notes. “In fact, the SFC in Hong Kong is proposing to introduce measures to require HK licensed fund managers to consider climate-related risks in their investment and risk management processes.”
Hodson also expects to see greater levels of sustainable investment in 2021. “In Standard Chartered Private Bank’s ‘Sustainable Investing Review 2020’ report, a survey of around 1,000 investors with a focus on affluent and HNW investors in Singapore, Hong Kong, the UAE and the UK, found that 90 percent of respondents in Asia said they are interested in sustainable investments and 42 percent plan to invest between 5 and 15 percent in this area over the next three years. The pandemic has accelerated and highlighted the importance of sustainability and ESG factors as a business strategy for some of the world’s largest companies and this is not a momentum I expect to slow even as we come out of the pandemic,” she says. “The growing legal and regulatory consensus that ESG is a factor to be considered when investing means that ESG is expected to be a focus for investors in Asia, and managers will need to manage such expectations.”
Hodson believes that this is an opportunity for offshore law firms to play their part as well. “Just as is the case for the businesses we advise, law firms need to consider how they build resilience to ensure sustainability,” she says. “We have an active focus on D&I, the environment and wellness, in addition to our investment in technology and client services. The environment has become a particularly big focus for us. We are building an environmental management system for the firm and have hired a head of sustainability to lead this process.”
TIME TO SHINE
As their clients have innovated and adapted to weather a succession of challenging situations, so have offshore law firms. “This is a time of unique opportunity to reshape the way offshore lawyers work with their clients and rethink the structure and scale of our practice areas, sectors and geographical locations,” says McKenzie of Carey Olsen. “Law firms with strong knowledge of their clients’ businesses will be better placed to weather the pandemic and react quickly. In addition, law firms that recognise the value of a ‘communication-driven’ culture will have an added dimension of resilience and will find themselves better placed to evolve and more effectively collaborate with their staff and clients. For those offshore law firms who are innovative, flexible and invest in technology, the pandemic experience will build goodwill and brand loyalty from both their clients and their employees.”
Hodson of Ogier says that given the significant number of regulatory changes at the start of the year, it was important to continue to reach clients and support their needs as efficiently as possible. “Technology was very much at the forefront of the solutions,” she recalls. “We were quick to move to online seminars, rolling out educational series at the start of the year and continued to deliver these over the course of the year. Further, Ogier’s IT infrastructure and common use of tested platforms allowed us to facilitate a timely move to remote working and online deal completion.”
“Ogier has been using an electronic signature product for some time now and we were able to roll this out to clients who were unable to provide wet ink signatures. Fortunately, the Cayman Islands has been well placed to adjust to the move to the signature of documents in electronic form having introduced the Cayman Islands Electronic Transactions Act in 2003,” Hodson adds.
She also points out that there were high levels of collaboration between offshore law firms as they came together to ensure that the raft of new regulatory changes for the funds industry in the BVI and Cayman Islands was dissected and disseminated in a clear and as consistent manner as possible to support the industry. “It was very much an industry-first mentality, and this was particularly important with clients under so many other strains this last year,” says Hodson.
“Whilst there have been many downsides to the lack of face-to-face interactions in the industry there has also been a resulting efficiency benefit. As an example, we have been able to attend more conferences this last year than ever before and across a wider number of jurisdictions as we have been able to do so from the comfort of our homes and offices. However, online forums don’t offer the same networking opportunities and so extra efforts have been required to stay connected and to continue to expand our connections,” she notes.
Alexander of Conyers says that the firm will continue to provide offshore assistance to clients in order to meet their business needs. This premise has driven, and will drive, our legal offering in Asia,” he notes. “The strength of our offshore services is reflective of the strength and breadth of the offshore jurisdiction premise itself, namely, to provide a stable, well-regulated, flexible platform which can provide offshore entities to meet our client business requirements.”
WHAT TO EXPECT IN 2021
Looking ahead, McKenzie of Carey Olsen says that he anticipates investors in the region will continue to allocate investment capital to alternatives. “We expect that China will continue to be the source of significant offshore deal flows, ranging from Chinese fund managers launching offshore funds, to joint ventures, IPOs on the STAR Market, promoter-led take-private deals, preference share financings and large global M&A transactions. Cayman and BVI structures, in particular, continue to have a central role in these deal flows, having already become embedded in Chinese structures since the late 1980s, and Chinese managers and investors remain responsive to innovative fund and other products introduced by these offshore jurisdictions,” he notes.
Padarin adds that economic down-turn that has resulted directly from the pandemic has increased the number of companies in the Asia-Pacific region which are suffering financial distress. “In the past six months we have seen a significant increase in the number of restructuring and insolvency-related instructions (both contentious and non-contentious) and would expect this trend to continue for at least the next 12-24 months as the economic effects of the pandemic shake out,” he notes. “From the perspective of the funds management industry, this has spawned opportunistic acquisition funds looking to acquire assets at distressed levels and/or acquire secondary interests in existing funds at discounted valuations.”
Meanwhile, Alexander predicts that the growth in Cayman funds will be in step with the recovery of the economies in Asia. “Such recovery will be affected significantly by the ability of a jurisdiction to manage the impact of COVID-19, including the ability to implement a vaccination roll-out. Some jurisdictions in Asia have been more effective at handling this and, subject to new local outbreaks, will be better positioned in 2021,” he says. “The recently reported 2.4 percent GDP growth for China’s economy is likely to set the global bar for 2021.”
For Hodson, the start of 2021 has demonstrated a significant amount of pent up activity, and her firm has been experiencing a very busy January with a significant number of new fund launches kicking off and new enquiries. “We are cautiously optimistic about the 2021 pipeline,” she says. “Another key trend is likely to be China-focused activity with the further opening up of China to foreign investment, allowing foreign firms to take majority stake ownerships in securities and fund management firms.
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