The "Unusual Moment" of a 10-Billion Private Fund

The "Unusual Moment" of a 10-Billion Private Fund

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A well-known private equity institution whose team's history dates back to 1999, with more than ten years of private equity registration history and peak entrusted scale exceeding ten billion RMB, is now in the predicament of "missing registered executives" and "scale falling below ten billion".

This certainly draws attention and invokes sympathy.

In 2024, the institution publicly announced that it had received an industry award. Back in 2020, its core investment personnel even gave a long interview describing their unique investment system.

But moving forward to 2025 and 2026, whether it’s the absence of registered executives or the company’s involvement in litigation, all make people feel the institution is "atypical" to some extent.

Looking back at the evolution and development of this institution, it is apparent that major market fluctuations, shifts in industry style, and personnel changes seem to have laid the "groundwork" for today’s story, but what truly determines the company’s next step remains their business.

As a well-known private equity institution in the industry with a hundred billion RMB scale, what situation are they currently in?

Latest entrusted scale below one hundred billion

According to industry sources, the aforementioned institution is Shanghai Bao Yin Private Fund (referred to as Bao Yin Private).

Business records show that this institution was established in 2014, located in Shanghai, mainly engaged in capital market services, with registered capital of 10 million RMB, previously named Bao Yin Investment.

Private fund registration records reveal more information. According to industry association data, the institution completed association registration in 2015. As of January 2025, entrusted scale is 5-10 billion RMB, with 35 full-time employees.

Three key positions, missing two

But closely examining the registration data, some distinctive "details" can be found.

Usually, for private equity institutions registered with the fund industry association, the key positions are:

First, legal representative/executive partner, responsible for the main entity responsibility, business and legal representation, and final decisions.

Second, senior management in charge of investment management, who leads the specific investment business.

Third, compliance and risk control leader, an independent position (cannot be concurrently held with investment business), responsible for compliance and risk control, legal affairs, internal control, anti-money laundering, and information reporting.

For “legal representative, executive partner or their appointed representative, and senior management responsible for investment management,” the relevant "Management Measures" require these executives to hold a certain proportion of shares in the private equity institution, have a good credit record, and possess professional competence matching their role (see below).

However, Bao Yin Private currently only has a specific name for the legal representative position in registration, with one key position "pending institutional change" and another not recorded at all.

This situation is quite rare among industry institutions.

Executive “termination of change”

There are more details in the registration information:

The registration information page shows: the private equity institution submitted a major change request for executive information in December 2025, but the latest status is “termination of change”.

At least according to the record on the page, the registered institution should have proposed an executive replacement at some point, but the move has now been terminated.

As for whether this was due to personnel not meeting requirements, association not approving, or the institution voluntarily withdrawing the application, outsiders do not know.

According to industry practice, it’s uncommon to propose an executive change and then “terminate” it.

Warned by regulators in 2024

Historically, some executives of this private equity have received warning letters from relevant regulatory authorities.

In July 2024, the Shanghai Securities Regulatory Bureau issued a decision requiring rectification measures for the institution, and warning letters for two executives.

The decision stated: in carrying out private equity fund business, the institution delegated fund investment management responsibility to others, which violated Article 27, Clause 1 of the "Private Investment Fund Supervision Management Regulations" (State Council Order No. 762).

Private fund managers delegating investment management responsibility theoretically means the institution gave up its own active management responsibility, constituting a noncompliant outsourcing behavior, something very rare in the industry.

The "named" Bao Yin Private executives were Li Mo and Bao Jiarong.

Notably, the penalty announcement stated: "(Bao Jiarong) as then compliance and risk control leader, was responsible for the above violation."  

As of the evening of March 4, Bao Yin Private’s registration staff list still did not include Bao Jiarong. Meanwhile, the registration executive information did not have a specific candidate for compliance and risk control leader.

Board registration list changed several times

Business records on Tianyancha show that months before the regulatory warning disclosed in 2024, the directors registration of Bao Yin Private saw changes.

Bao Jiarong, the compliance and risk control leader, left the directors list, and another person named Wang Qiang also exited the directors list (see below).

According to "Private Equity Ranking Net", Wang Qiang founded PINPOINT in 1999, expanding domestic asset management business and providing professional asset management to domestic investors. Later he moved to Hong Kong, expanding overseas asset management business for foreign investors.

PINPOINT is Bao Yin Private Fund’s English translation, and their public email suffix also includes this term. But the legal relationship between the two and Bao Yin Private currently remains to be clarified.

According to Tianyancha: the People's Court of Changning District, Shanghai issued a public hearing announcement on January 22, 2026, involving Bao Yin Private, Ren, Sun, and Li in an illegal business criminal case.

But based on limited public information, the industry is currently unaware of the nature of the case or the trial progress.

Still publishing research views externally

Notably, as of the latest registered disclosure, Bao Yin Private’s current management scale is in the range of 5-10 billion RMB, remaining at this level since early 2025.

Previously, this private equity was one of the representative hundred-billion private institutions, also having overseas teams in Japan, India, and Singapore, and had once recruited the chief economist of a major international investment bank for key positions.

If the above scale is still the latest, it means their managed scale remains quite adequate.

Additionally, their official WeChat account is updated regularly. The latest article published is "Butterfly Effect of the Strait of Hormuz: Global Supply Chain Disruption and Second Inflation Surge", which is quite an in-depth analysis, showing the team’s significant research capabilities.

Recruitment notices with some "highlights"

Furthermore, in the recruitment information disclosed on Bao Yin Private's official website, the latest update for full-time job postings was in August 2024, and for interns, October 2025.

The intern recruitment is for fundamental research analyst, with requirements including "passion and motivation for buy-side and hedge fund research, sustained and solid learning ability," with no professional background specified.

The notice describes a clear path for the intern’s growth: "The goal is to train research analysts over a period in different phases to become independent fund managers, including independent mock portfolios, live exercises, scaled portfolio management, and potential team building."

In addition, in October 2025, there was a recruitment for a marketing department intern to maintain existing self-media platforms.

At least according to recruitment info, at that time Bao Yin Private’s operational focus seems to have shifted from large-scale expansion to supplementing the core team.

Risk Disclosure and DisclaimerThe market presents risks, investment needs caution. This article does not constitute personal investment advice, nor does it consider individual users’ special investment goals, financial situation, or needs. Users should consider whether any opinions, viewpoints, or conclusions in this article fit their particular circumstances. Investment based on this, at your own risk. ```