The public is still ambiguous: 200 people limit is the biggest obstacle to universal VC reality very bone

"Private equity public financing management measures (trial) (draft)" successfully launched, indicating that the regulatory layer finally clear the position of the industry development, will have a significant impact on the development of the industry. Before fully understanding the impact of the draft, it is necessary to make a macro analysis of the financial innovation business represented by "public-raised". The problems and opportunities of the domestic financial industry are embodied in the system of the old system to protect the "pro-son". In the investment end, to suppress the cock silk, reduce the cost of capital acquisition, in the financing side squeeze private enterprises, improve the financing difficulty of private enterprises. This is the nature of repression in the domestic financial industry. But the nature of capital is profit-driven, it cannot be suppressed, but it exists forever. In the balance of treasure as the representative of the Internet finance turned out before, this can not be repressed nature of private lending this form of tenacious existence. Even "pro-son", there is a large number of lending loans to earn spreads. It is the profit-driven nature of capital that ensures efficient allocation of capital resources: from low efficiency and low growth to high efficiency and growth goals. This is the core of domestic financial innovation, so that the invisible hand in the allocation of capital resources play a leading role. It is also the essential meaning of the so-called financial service entity economy. From the balance of treasure, to Peer-to-peer, and then to the public, its core business logic reflects the property of profit, that is, the invisible hand to dominate the allocation of capital. After analyzing the innovation nature of the domestic financial industry, we can clearly see that any policy of the regulatory layer, if it helps the invisible hand to play a role, will play an active role in the industry innovation, if the attempt to curb the invisible hand to play a role, will delay or even hinder the development of financial innovation. Based on this, we have a neutral optimism for the review of the regulatory level, outlined as the trend but cautious and different. The so-called conform to the trend, the performance of the draft for the development of the industry support and innovation necessary to contain and "ambiguous." The biggest highlight of the draft is a clear equity platform for the filing system. Fully embodies the draft for the development of the industry support. The sixth article "record registers" the stock raising platform should register in the Securities Industry Association, and applies for the Securities Industry Association member. The 16th article "The record document" The stock-raising platform should be in the establishment 5 working days after the Securities Industry Association applies for the record, and submits the following documents. At the same time, we believe that the draft in the public to raise key business points of innovation, to maintain an inclusive and necessary "ambiguous", specific performance in: The nature of the Non-public offering 200 people limit although this request for comment Draft clearly elaborated, not to the specific personnel publicity projects. However, when defining a specific person, the expression is: "Through the platform certification through the public", "Meet the investment requirements", "real name registered users." In practice, the use of the Internet and other emerging media, publicity platform itself did not touch the policy and regulatory red line. In this way, the public propaganda platform has reached the goal of public propaganda, and fully demonstrated the acceptance of the draft for industry innovation. Second, the 200-person shareholding restriction is a huge obstacle to the public financing business to the Universal VC. Although theThe draft made it clear that the number of holders must not exceed 200, while the ban on public-funded platforms for the public to provide equity generation, but we also found that the provisions of the "ambiguous": there is no clear definition of whether 200 people to carry out penetration inspection. Explain that the regulatory layer has left enough room for innovation. Discreet prudence is mainly manifested in the strict definition of qualified investors. Theoretically speaking, the relevant provisions completely eliminate the possibility of cock silk participation, universal VC become a distant dream. This suggests that regulators are extremely wary of the potential risks to the general public's participation in the equity community. The so-called closeness and intimacy are mainly embodied in the prohibited behavior of the platform of equity, that is, method Nineth. The Nineth section of the sixth paragraph is called the most ambiguous draft of this request for comment, not one. The foregoing prohibited acts include the external guarantee and equity holding of the public-funded projects, the two transfers of the shares, and the promotion and referral of financing items to the unregistered users, except those with relevant business qualifications. This essentially licensing access, in the short term will give the securities institutions a huge institutional competitive advantage, really achieve a difference between intimacy. To sum up, this draft fully explained that the regulatory level has recognized that financial innovation is the general trend, accepted the basic trend of industry development. This is the central reason why regulators need to be ambiguous about business-critical points. But at this point in time, the regulatory level is conservative and cautious as the keynote, while the introduction of a different competition strategy, hoping to foster the existing securities institutions in the competition to gain advantage. Universal VC, still a long way to go.