Does receiving KOSDAQ IPO shares also help a fund meet the new share requirement?

It can. In 2018 materials, the Financial Services Commission analyzed, by fund size, how much KOSDAQ IPO allocations contribute to meeting a fund's obligation to hold new shares, and concluded that the larger the fund, the smaller the allocation relative to net assets, making it hard to meet the requirement with IPO shares alone.

Offered shares can include existing shares sold by current shareholders as well as new shares, so the asset manager determines the actual calculation according to the Enforcement Decree.