Recently, Suxiang (Cayman) received feedback from the China Securities Regulatory Commission (CSRC) regarding its overseas listing filing. The specific feedback is as follows, requesting the company to provide supplementary explanations on the following matters, with lawyers required to conduct verification and issue clear legal opinions:
1. Please explain: (1) The compliance of the equity control structure establishment, including but not limited to the specific circumstances of relevant entities involved in the construction and round-trip investment fulfilling regulatory procedures for foreign exchange management, overseas investment, foreign investment, and tax declaration, and whether they comply with the "Provisions on the Merger and Acquisition of Domestic Enterprises by Foreign Investors"; (2) The similarities and differences between the issuer's common shares and preferred shares, whether there are special rights arrangements and their impact on company operations and control.
2. Please explain: (1) The standard basis for determining domestic main operating entities; (2) Regarding the situation where domestic operating entities have unpaid registered capital, please provide supplementary explanations on the reasons and compliance; (3) In conjunction with franchise contracts, further explain the franchise business model and compliance situation; (4) The status of websites, apps, mini-programs developed and operated by your company, the scale of user information collection and storage, data collection and usage, whether there are circumstances of providing information to third parties, and arrangements or measures for protecting personal information and ensuring data security before and after listing.
3. Please explain the determination basis and reasonableness of the number of shares issued and the amount of funds raised in this offering, and provide supplementary explanations on the valuation levels of similar companies in domestic and overseas markets, roadshow and bookbuilding situations.