On 22 February 2019, the China Securities Regulatory Commission ("CSRC") issued a consultation draft of the Guidelines on Manager of Managers Products for Institutions Engaged in Securities or Fund Business (《证券基金经营机构管理人中管理人(MOM)产品指引(征求意见稿)》 (the "MOM Guidelines") to solicit public comments. While MOM products are not new in international securities markets, they represent an innovative fund product for China.