Source: China National Fund Report
Author: Lu Huijing，Fang Li
In the past two years, the Trading Open Index Fund (ETF) has been greatly developed and its scale has risen gradually as well. More and more listed companies have bought ETF shares for stocks, and there is also over-proportional redemption. The reporter learned from the industry that the regulatory will make the window guidance for "ETF redemption" to regulate the over-purchase behavior, which requires that the change-over scale should not exceed the weight of the component shares in the index, and should follow the relevant provisions of the shareholders' reduction of listed companies.
According to the insiders of fund industry, it is conducive to the long-term healthy development of ETF products for purchasing the exchange of ETF products.
Regulating ETF Redemption
"Recently, it is said that window guidance on the redemption of ETF is mainly aimed at the restriction on the redemption of listed companies, which cannot exceed the index weight, and the large-value redemption requisition needs to be submitted to the relevant authorities for approval." The insiders of a fund company said.
However, there are also fund companies that have not received a window guidance on ETF redemption. "The regulators may only provide window guidance for some companies."
An ETF fund manager in Shanghai said that if the share of the listed company exchange the ETF shares could not exceed the index weight, it would have a great impact on the ETF redemption, and it would be difficult to carry out the redemption in the future.
"The 1 billion issuance scale of ETF, listed companies accounted for 5% of the index weight, and the redemption amount of the listed company's shareholders was 50 million. For this purpose, listed companies also need to publish announcements and experience a complex process that shareholders of listed companies do not necessarily want to participate. On the other hand, it is also unlikely that many ETF products will be released at the same time, and the shareholders of listed companies are difficult to find more ETF redemption at the same time to meet the needs of the company's for a large proportion of one-time redemption." Examples analyzed by the fund manager.
Another fund company's person also said it was difficult to issue the ETF products in the past, and the difficulty of issuance would increase once the ETF redemption was restricted. However, ETF products are more suitable for continuous marketing, and the initial scale is relatively less important. If a larger scale is obtained through short-term excess redemption, the relevant funds may be evacuated after a period of time. It not only affects the normal operation of the fund, but also has a unfair value for other holders, which is regarded as a long-term loss. Regulating the over-proportional redemption can guarantee the long-term and healthy development of ETF.
Since this year, the situation of redemption of ETF by shareholders of listed companies is becoming more intensive. According to Wind data, eight listed companies have issued announcements since October that the shareholders plan to participate in the purchase ETF under the network, involving multiple ETFs.
Judging from the proportion of purchase, the amount of redemption in many listed companies is over their index weights. While in some parts of redemption ETF, its net value performance was significantly fall behind the index, which is exposing the drawbacks of over proportional redemption to investors.
"The performance of ETF's established period shows a significant backward than index, mainly due to two reasons: first, the net value of the fund is seriously deviated from the index, caused by the over redemption of shares, and the deviation may be backward or the leading index performance; Second, due to the rhythm of the establishment of the fund, for example, establish the position in the high point of the market, but in general, when ETF is not traded in the secondary market before the listing, investors can not withdraw, and the fund manager will not establish the position until eve of ETF listed. "Analysis of the product department of a fund company.
"In terms of the perspective of shareholders, Good stocks will certainly continue to hold. The stock exchanged by the shareholders should be more common." The above mentioned by Shanghai ETF fund manager.
If the proportion of redemption is too high, it should not be marketed to the retail market.
"The fund company should not make a single share too high when the new fund is issued, which could expose the risk exposure of fund operation." According to the Director of the index Investment Department of a fund company. "In theory, when the ETF is listed, the fund manager should adjust the individual proportion to in line with the tracking index, and we also do not need to wait for the listing, but adjust the proportion of open interest when the fund established in one-time. "
An ETF fund manager in Shenzhen expressed his approval for the regulation of ETF redemption He said that: "After the regulation, the fund company and fund manager can be protected to avoid the risk of being complained."
In response to the phenomenon of over redemption, resulting fund's net value largely deviate from the index, an ETF fund manager of Beijing suggested that the fund company needed to weigh between the ETF tracking error and the redemption ratio when accepting the stock exchange of listed companies. In addition, the fund company itself also has the right to reject stock exchange for listed companies with poor quality. In case of a poor quality of a listed company, the fund company should dare to "vote with foot".
He also suggested that if the proportion of single share in ETF was too high, the fund company should not promote the cash subscription to small and medium-sized investors during the issuance period, so as to avoid the large-scale tracking error between ETF and the index under established period, thus damaging the interests of small and medium-sized investors.
In addition, there is a fund company market person expressed that ETF distribution is mainly targeted at institutional investors such as listed companies, brokers and financial companies, and if there is an over-redemption of listed companies, it is not suitable for small and medium-sized investors to participate.

超比例换购受限！ETF市场迎来重要变革
来源：中国基金报
作者：陆慧婧 方丽
近两年，交易型开放式指数基金（ETF）获得大发展，规模节节攀升。越来越多的上市公司以股份换购ETF份额，当中也出现了超比例换购的现象。记者从业内了解到，监管层或对换购ETF进行窗口指导，规范超额换购行为，要求换购规模不得超过该成份股在指数中的权重，同时换购要遵守上市公司股东减持的相关规定。
基金业内人士认为，规范ETF产品换购，有利于ETF产品的长期健康发展。
规范ETF换购
“近期听说在对ETF换购行为进行窗口指导，主要是针对上市公司换购的限制，不可超过指数权重，而且大额换购需要上报相关机构批准。”一家基金公司产品人士说。
不过，也有基金公司人士表示，并未接到关于ETF换购的窗口指导。“监管层可能只是针对部分公司进行了窗口指导。”
上海一位ETF基金经理表示，若上市公司股份换购ETF份额不能超过指数权重，将会对ETF换购业务带来较大影响，未来换购将很难开展。
“发行规模10亿的ETF，上市公司占指数权重达到5％，上市公司股东能够换购的金额为5000万。为此，上市公司还需要发布公告，经历一个复杂的流程，上市公司股东不一定愿意参与。另一方面，也不太可能有那么多ETF产品同时发行，上市公司股东很难同时找到多只ETF换购，满足公司一次性大比例换购的需求。”该基金经理举例分析。
另一位基金公司产品人士也表示，过去ETF产品发行比较困难，一旦限制ETF换购，发行难度还会加大。不过，ETF产品更适合持续营销，首发规模相对不那么重要。如果通过短期超额换购获得较大规模，一段时间之后相关资金方可能就会撤离。不仅影响基金的正常运作，对其他持有人来说也有失公平，长期看是得不偿失。对超比例换购做出规范，可以保障ETF长期、健康的发展。
今年以来，上市公司股东换购ETF的情形愈发密集。Wind数据显示，10月以来就有8家上市公司发布公告称股东计划参与ETF网下认购，涉及多只ETF。
从换购比例来看，不少上市公司换购金额都超过了其所占指数的权重。而部分参与换购的ETF净值表现大幅落后于指数，将ETF超比例换购带来的弊端暴露在投资者面前。
“ETF建仓期业绩表现大幅落后指数，主要有两方面的原因，一是换购个股超标导致的基金净值表现严重偏离指数，偏离可能是落后也可能是领先指数表现；二是基金建仓节奏所导致的，例如在行情高点建仓，但一般情况下，ETF上市前不在二级市场交易，投资者无法退出，基金经理都会等到ETF上市前夕才建仓。”一家基金公司产品部人士分析。
“站在上市股东角度看，好的股票肯定会愿意继续持有。股东拿出来换购的股票，质地应该比较一般。”上述上海ETF基金经理说。
换购比例过高不宜向散户推销
“基金公司不应该在新基金发行时，让单一个股占比过高，会暴露基金运作的风险敞口。”一家基金公司指数投资部总监称，“理论上说，ETF上市时，基金经理应该将个股占比调整到与跟踪的指数一致，而且也可以不用等到上市，在基金成立时将持仓占比一次性调整好。”
深圳一位ETF基金经理表示赞同对ETF换购进行规范。他说：“规范之后，可以对基金公司和基金经理形成保护，规避被投诉的风险。”
针对换购超标导致基金净值大幅偏离指数的现象，北京一位ETF基金经理建议，基金公司在接受上市公司股票换购时，需要在ETF跟踪误差和换购比例之间有所权衡。此外，基金公司本身也有拒绝质地较差的上市公司股票换购的权利。当出现上市公司质地较差的情况时，基金公司应该敢于“用脚投票”。
他还建议，若单一个股占ETF比重过高，基金公司就不应在发行期间向中小投资者宣传现金认购，避免ETF在建仓期与指数之间跟踪误差较大，损害中小投资者利益。
此外，还有一家基金公司市场人士表示，ETF发行主要是针对上市公司、券商、财务公司等机构投资者，若存在上市公司超额换购的情况，则不适合中小投资者参与。