Banma Network Receives Feedback from CSRC for HKSE IPO, Addressing Seven Key Issues Including Equity, Business, and Compliance

Deep News
Oct 20, 2025

Recently, Banma Network Technology Co., Ltd. received feedback from the China Securities Regulatory Commission (CSRC) regarding its application for overseas listing. The CSRC requested the company to provide additional explanations on several matters, verified by legal counsel to issue definitive legal opinions. The specific feedback is as follows:

1. **Equity Changes**: (1) Explain the pricing basis for the company's previous capital increases and equity transfers, whether the pricing was fair, whether actual contributions were made, and if there were any issues related to unfulfilled obligations, withdrawal of contributions, or flaws in the contribution methods. Provide conclusive opinions on compliance regarding the establishment and changes in equity. (2) Update on the progress of the company's capital reduction and increase registered with the industry and commerce in August 2025, compliance of the reduction process, payment of related taxes, and the payment status of the reduction consideration.

2. Confirm whether the company has state-owned shareholder identification obligations that have not yet been completed and provide clear conclusions from legal counsel regarding the existence of state-owned shareholders.

3. **Business Operations**: (1) Clarify the company’s and its subsidiaries' operational scope, which includes “value-added telecommunications services; market research; surveying services; advertising through media; advertising production; advertising publishing; and advertising design and agency.” Confirm whether these activities are actually conducted, whether necessary licenses have been obtained, collaborations with third parties, the partner names (and if they hold qualifications), methods of collaboration, and compliance with the Special Administrative Measures for Foreign Investment Access (Negative List) (2024 edition). Ensure that the issuance and listing, along with “full circulation,” comply with foreign investment access requirements. (2) Update on the progress of the subsidiary Ban Zhiyun Tu’s “Pilot Value-Added Telecommunications Service Operating License” and detailed plans for related business. (3) Describe the business model and specific details involving large language models in understandable terms, and confirm whether the related large model fillings have been completed.

4. **Standard Operations**: (1) Clarify whether the company and its subsidiaries are involved in developing and operating websites, mini-programs, apps, and public accounts, and whether they provide information content to third parties. Include types of information content, security measures for data protection, as well as the scale of user information collected and stored, usage of data, and arrangements for personal information protection and data security before and after listing. (2) Provide the latest updates on any ongoing litigation or arbitration cases involving the company and its subsidiaries, indicating if they could pose substantial obstacles to the overseas issuance and listing.

5. Strictly align with the provisions of Article 8 of the Interim Measures for the Administration of Overseas Issuance and Listing by Domestic Enterprises to confirm whether there are any prohibitive circumstances for the overseas issuance and listing of the company and its domestic subsidiaries.

6. Regarding the current issuance and “full circulation”: (1) Explain the estimated amount of funds raised if the overallotment option is fully exercised; (2) Clarify whether the shares held by the shareholders participating in this “full circulation” are subject to pledge, freeze, or other rights issues.

7. Provide information on the regulatory procedures for the company's spin-off listing in the proposed market.

Disclaimer: This message is a reprint from Sina’s cooperative media and is published by Sina.com for the purpose of conveying more information, and does not imply approval of its views or confirmation of its descriptions. The content of the article is for reference only and does not constitute investment advice. Investors act at their own risk based on this information.

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