New dynamics are unfolding in the A-share market, with the private fund circle witnessing the emergence of "invisible whales." The most influential institutions in the A-share market have traditionally included state-backed mega investment entities, the social security fund, major insurance groups, large public fund managers, top foreign institutions, and leading quantitative investors. A new category is now joining their ranks: ultra-large private fund institutions.
An analysis of the ultimate holders of public fund ETFs as of the end of 2025 reveals that top-tier private fund firms have begun making collective, bulk, and substantial entries into related products. The leading firm's holdings have already reached a scale of nearly 10 billion yuan. Given the disclosure rules for public fund products, this often indicates that these institutions possess even more impressive holding scales, positioning them alongside existing mega-institutions as dominant market forces. While most investors remain focused on the inflows and outflows of northbound capital or subtle shifts in public fund portfolios, a "storm" is quietly brewing within the "teacup" of the private fund world.
An entity named Beijing Chengyang Investment Co., Ltd. (hereafter "Chengyang Investment") has quietly appeared and risen to become the most significant private fund investor in the ETF market, as shown in 2025 fund annual reports. Third-party data indicates that Chengyang Investment appears in the top-ten holder lists of at least 21 ETFs, with exceptionally large holding amounts. According to China Securities research, by the end of 2025, a total of 193 private fund firms appeared in the top-ten holder lists of 390 ETFs, holding approximately 14.532 billion shares collectively. Chengyang Investment led the pack with 7.876 billion shares, commanding nearly half of the private fund holdings.
A detailed review shows that Chengyang Investment's heavy portfolio holdings in the fund market are quite broad. They include representative broad-based ETFs such as the CSI 300 ETF, CSI 500 ETF, and ChiNext ETF. They also cover thematic ETFs in the technology sector, such as those focused on chips, the digital economy, consumer electronics, and robotics—the latter being among this year's top performers. Additionally, the firm holds resource-focused ETFs like non-ferrous metals, rare earths, and rare metals, as well as Hong Kong market ETFs like the Hang Seng Internet, Hang Seng China Enterprises, and Hang Seng Consumption ETFs. It even holds ETFs for sectors like gaming and securities. The variety of holdings, the scale of allocated assets, and the sectors and proportions all point to one possibility: this institution wields significant market influence.
Chengyang Investment, seemingly appearing out of nowhere, has suddenly dominated the ETF market with holdings valued in the tens of billions, drawing considerable attention within investment circles. Association of Fund Industry registration information shows that Chengyang Investment was established in 2017 and completed its private fund manager registration in August 2020. Its current management scale has exceeded 10 billion yuan—the maximum registration caliber for private fund firms, which does not necessarily reflect the actual amount under management. As a third-party observer, it's evident that this seemingly low-profile private fund firm has substantial backing. Its actual controller is China Chengtong Holdings Group Co., Ltd.
Official information indicates that Chengtong Group was established in 1992 through the merger of state-owned logistics enterprises directly under the former Ministry of Materials. It was responsible for the procurement, allocation, warehousing, and distribution tasks of important state production materials under mandatory plans. In 2005, the State-owned Assets Supervision and Administration Commission designated China Chengtong as a pilot for state-owned asset management companies. Currently, this central state-owned enterprise group is positioned as a "market-oriented professional platform for the flow, reorganization, and layout adjustment of state-owned capital." In other words, Chengyang Investment is not an ordinary secondary market private fund. It has a strong shareholder background and may even bear the mission of preserving and increasing the value of state-owned assets. Furthermore, Chengyang Investment's legal representative is Wang Lingli, who previously served as the general manager of the equity management department at Chengtong Group, bringing deep experience in state-owned equity operations. This explains how Chengyang Investment could mobilize such vast funds in a short period to strategically position itself across major ETFs, backed by one of the most powerful "central enterprise aircraft carriers" in China's capital market.
A detailed breakdown of Chengyang Investment's portfolio structure reveals that broad-based index funds occupy an absolute core position. Based on data from the end of last year, the firm's key year-end holdings in broad-based index-related instruments included four CSI 300 ETFs, three CSI 500 ETFs, and one ChiNext ETF. Taking the year-end holder status of the three largest CSI 300 ETFs by industry scale—Huatai-PineBridge CSI 300 ETF, E Fund CSI 300 ETF, and ChinaAMC CSI 300 ETF—as an example, Chengyang Investment appeared four times across these three key funds at year-end, holding nearly 600 million shares in total, with a holding value comparable to that of top insurance capital institutions.
From the currently exposed accounts, Chengyang Investment's structure includes at least several sizable accounts, such as the Chengyang Flexible Allocation Private Fund, Chengyang Smart Allocation Private Fund, Chengyang No. 1, Chengyang No. 2, and Chengyang Strategic New Industry Fund, among others. This also suggests another possibility: given the limitations on the disclosure level of holding accounts, the currently published holding amounts for Chengyang Investment represent just the "tip of the iceberg" of this private fund firm's ETF and equity asset holdings, with its actual portfolio likely being far larger than the disclosed figures.
Moreover, this "scattergun" approach to portfolio construction and strategy closely resembles the historical methods of quasi-market stabilization funds and large insurance capital institutions. Considering Chengyang Investment's strong state-owned asset background and its appearance alongside institutions like Central Huijin in holder lists with holdings valued in the tens of billions, the potential functions this institution might undertake are thought-provoking. This phenomenon sends a clear signal: as various long-term funds gradually enter the market, the concept of institutions undertaking "stabilization functions" is expanding—the stabilizing forces in the capital market are continuously strengthening. When "state-affiliated" capital heavily invests in these broad-based ETFs, it also seems to signify the growing importance of ETFs within the market stability system.
In simple terms, a broad-based ETF is like a "super fruit basket" filled with leading companies from various industries. Buying it equates to a one-click purchase of the core assets of the Chinese economy, providing a "floor" for the capital market and further boosting long-term investor confidence. This approach is being embraced by an increasing number of long-term institutions.
Beyond the distinctly state-affiliated Chengyang Investment, another investment institution drew significant attention among ETF holders in the 2025 annual reports. Holding the second-largest position is Hengyi Chiyin (Shenzhen) Private Fund Management Co., Ltd. (hereafter "Hengyi Chiyin"), with holdings amounting to 1.963 billion shares, second only to Chengyang Investment. Observation reveals that Hengyi Chiyin's investment approach differs markedly from Chengyang Investment's; it focuses its attention on money market ETFs. Data shows that this private fund firm appears in the top-ten holder lists of the Yinhua Daily Earnings Money Market ETF and the HuaBao Tianyi Money Market ETF, with the scale of the Yinhua Daily Earnings ETF exceeding 70 billion yuan. This allocation clearly indicates that Hengyi Chiyin is using money market ETFs as a "reservoir" for its substantial funds, balancing liquidity management with basic returns.
This private fund firm also has notable origins. Information shows that Hengyi Chiyin was wholly established by the Ping An Insurance Group and officially completed its registration in August 2025. Currently, the institution has only five full-time employees, yet its management scale has surpassed the 10 billion yuan mark, and it has registered only one product. This "minimalist" team structure paired with a "massive" fund scale is a typical characteristic of insurance capital-affiliated private funds. Insurance capital-affiliated private funds have previously been confirmed to possess the potential for enormous fund sizes. For instance, Honghu Fund (managed by Guofeng Xinghua), a joint venture established by New China Asset Management and China Life Asset Management, has been confirmed to potentially have a scale exceeding 100 billion yuan.
Interestingly, in the holder list of the Yinhua Daily Earnings Money Market ETF, Hengyi Chiyin and Chengyang Investment are "of one mind," both appearing within it. This reflects that, in the current market environment, both the "new national team" with industrial central enterprise backgrounds and those with insurance capital backgrounds are, without prior agreement, stockpiling ammunition through highly liquid instruments, quietly awaiting market opportunities.
It is worth noting that over the past year, securities-focused private funds under large listed insurance groups have become a significant force in China's private fund landscape. The most prominent representative under the spotlight was previously Honghu Fund, jointly established by China Life Insurance and New China Life Insurance, which has aggressively entered the core shareholder groups of several large-cap blue-chip stocks. Another interesting finding is that this "insurance capital shadow" is reflected in the Yinhua Daily Earnings Money Market ETF through an entity named "Beijing Lexi Private Fund." This Beijing-based private fund holds a substantial 7.38 million shares in this money market ETF. Based on the net asset value per share at the end of December last year, the holding value amounts to approximately 738 million yuan. More critically, Lexi Asset Management ranked third among private funds holding ETFs in the 2025 annual reports. The legal representative and investment head of this private fund, Yang Yang, worked at Taikang Asset Management from 2002 to 2015, serving as the managing director of stock investment in the equity investment department of this insurance capital firm.
This raises an important question: whether it's Hengyi Chiyin or Chengyang Investment, the act of deploying tens of billions of yuan into money market funds—a defensive posture of "stockpiling ammunition"—could it be amassing strength for a potential major market reversal in the future?