On November 28, the China Securities Regulatory Commission (CSRC) released its "Supplementary Material Requirements for Overseas Listing Filings (November 24–28, 2025)." The CSRC's international department issued additional disclosure requests to five companies, including Rayson HI-TECH (SZ) Co., Ltd., regarding equity changes, shareholder structure, and business operations.

According to a September 29 filing with the Hong Kong Stock Exchange, Rayson HI-TECH submitted a listing application for the main board, with China Merchants Securities International and Guotai Junan International serving as joint sponsors. The CSRC has requested Rayson HI-TECH to provide supplementary explanations on the following matters, with legal verification required:

1. **Equity Changes**: (1) The company must verify historical shareholding arrangements per regulatory guidelines. (2) The fairness of employee stock ownership plan pricing must be clarified, with a conclusive opinion on potential利益输送 (benefit transfer).

2. **Shareholder Structure**: (1) Justify the designation of Wen Jianwei as the sole controlling shareholder, addressing potential control changes post-IPO. (2) Update on the progress of state-owned shareholder标识 (identification) for Orient Securities Innovation.

3. **Business Operations**: (1) Confirm compliance with foreign investment restrictions pre- and post-listing, including "full circulation" arrangements. (2) Assess the impact of第三方付款 (third-party payment) arrangements on operations and IPO eligibility.

4. **Regulatory Compliance**: (1) Disclose any underpayment of social insurance/housing funds and evaluate material legal risks. (2) Provide updates on litigation affecting operations or debt repayment capacity.

5. **Listing Plan**: Further details on the IPO and full流通 (circulation) scheme under applicable regulations.

Per its prospectus, Rayson HI-TECH specializes in embedded storage products, including DRAM-based (DDR, LPDDR) and NAND Flash-based (eMMC, UFS) solutions, alongside multi-chip packaging (MCP) offerings. The company also produces SSDs, memory modules, and provides complementary testing/storage技术服务 (technical services).