New Trading Suspension Rule: A Double-Edged Sword
New Trading Suspension Rule:A Double-Edged SwordPresentation to INED17 October 2019Information Classification: Internal
Part I 2019. For information, contact Deloitte China.For internal discussion only2
What’s new about 13.50A (“new suspension rule”)Old regime 2019. For information, contact Deloitte adingIssuerNew regimeRegulatorFor internal discussion only3
Mainboard - 13.50A (GEM Listing Rule 17.48B)“The Exchange will normally require suspension of trading in an issuer’ssecurities if it publishes a preliminary results announcement for a financial yearas required under rules 13.49(1) and (2) and the auditor has issued, or hasindicated that it will issue, a disclaimer of opinion or an adverse opinion onthe issuer’s financial statements. The suspension will normally remain in forceuntil the issuer has addressed the issues giving rise to the disclaimer or adverseopinion, provided comfort that a disclaimer or adverse opinion in respect of suchissues would no longer be required, and disclosed sufficient information to enableinvestors to make an informed assessment of its financial positions.”“This consultation was about improving the quality and reliability of financialinformation of issuers to safeguard market quality,”“The new Rule encourages issuers to maintain appropriate and effective riskmanagement and internal control systems, and where necessary, requires themto act promptly to resolve issues with their auditors,”- David Graham, HKEX’s Head of Listing 2019. For information, contact Deloitte China.For internal discussion only4
Audit opinions that will trigger pinion withEmphasis ofMatter 2019. For information, contact Deloitte China.ModifiedOpinionQualifiedDisclaimerAdverseFor internal discussion only5
Example of disclaimerMaterial uncertainties related to issuer’s abilities to continue as agoing concernLimitation of scope on valuation of assets due to lack of books andrecords and/or supporting documents, etc. Failure to substantiate carrying amounts investment or otherfixed assets Certain books and records of the issuers being lost orinaccessible Fire or natural disaster resulting in loss of primary evidence De-consolidation of subsidiaries from the group’s consolidatedfinancial statements as the issues were unable to exercisecontrol over time and have no access to the books and records 2019. For information, contact Deloitte China.For internal discussion only6
Example of disclaimerDisclaimer Opinion (846) “ Management was not able to provide us with satisfactory explanations asto the commercial substance of these transactions, and provide us withadequate documentary evidences to support the nature and source of thesereceipts from and payments to the above company ” “ we have independently identified significant amounts of payments toand receipts from (including the payments and receipts described in theabove sections) a number of companies . Such payments and receiptswere not supported by legitimate documentary evidence. ” “Given the above, together with our concerns on those transactionsdescribed in the sections we have requested the board of directors of theCompany to form an independent committee to commission an independentinvestigation on the authenticity and commercial substance of thesetransactions (the “Proposed Investigation”) ” 2019. For information, contact Deloitte China.For internal discussion only7
Example of resignation of auditorAuditors cease work and resign (1007) Before the deadline for publication of the audited account, the Auditorsresigned. In the auditors’ letter of resignation, it was said: “We continue to haveconcerns about matters pervasive to the financial statements including (1) transactions brought to the attention of management and acknowledgedby them to be fraudulent; (2) unexplained differences between sales receiptnotes ; (3) the explanation provided by management for removingaccounting records which were then not available to us continuously duringthe audit; (4) the validity and commercial substance of acquisition.” The HKEx imposed a resumption condition for the Company to conduct aforensic investigation on the audit issues (including the certain potentiallyfraudulent transactions). 2019. For information, contact Deloitte China.For internal discussion only8
Exemption #1: Going concern The disclaimer or adverse opinion relates solely to goingconcernYear 1 Material uncertainties aboutthe company’s ability tocontinue as a going concernmaterial uncertainties about thecompany’s ability to continue as agoing concernDisclaimerYear 2 Completed an equityfundraising for repayment ofdebts and working capital, andissued convertible bonds tosettle certain amounts due tocreditors Improvement in the company’soperating performance duringthe yearClean Opinion with an emphasis of matterrelating to the going concern issue 2019. For information, contact Deloitte China.For internal discussion only9
Exemption #2: Issue resolved the underlying issue is resolved before the issuer publishesthe preliminary results announcement the audit issues would not have an ongoing effect on theissuer’s financial statements for the succeeding financial yearsFire accidentLoss of books andrecordsDisclaimerReconstructaccounting recordsPublication of financialresults for the year 2019. For information, contact Deloitte China.For internal discussion only10
Other highlightsEffective Date Apply to preliminary annual results announcements for the financialyears commencing on or after 1 September 2019Longer remedial period For issues remains unresolved outside the issuer’s control, HKSE mayallow longer remedial period, with the duration of the period beingdetermined on a case by case basis.Transitional Arrangement Extend the remedial period to 24 months for the financial yearscommencing between 1 September 2019 and 31 August 2021 2019. For information, contact Deloitte China.For internal discussion only11
New Trading Suspension RuleThe proactive and reactive approachesHow to prevent suspensionand delisting?Current Listing RulesMainBoardGEMSuspension18 months12 months(Prescribed remedial period)Proactive Identify and resolve the issues givingrise to disclaimer and or adverseopinions before publication of thepreliminary results announcement.Reactive Identify and resolve the issues givingrise to disclaimer and or adverseopinions within 18 months (or 12months for GEM issuers)Delist 2019. For information, contact Deloitte China.For internal discussion only12
Part II - Seeking a resumption 2019. For information, contact Deloitte China.For internal discussion only13
New delisting regime New delisting regime with an aim to delist prolongedsuspended companies became effective on 1 August 2018: 2019. For information, contact Deloitte China.For internal discussion only14
Recent regulatory updates The objective of the new delisting rules (Para. 8 of GL95-18) 2019. For information, contact Deloitte China.For internal discussion only15
What is the new delisting regime?Old Regime Delist a company immediately withoutsuspension (LR 6.10)New Regime Delist a company immediately (LR 6.10) Delist a company after a SpecifiedRemedial Period (LR 6.10)Delist a company after a specifiedremedial period (with a specific 3-stagedelisting procedures for PN 17 companies (being companies unable tocomply with LR13.24)) (LR 6.10) 2019. For information, contact Deloitte China.Delist a company for failure to remedythe issues causing its suspension oftrading, to re-comply with the rules andresume trading before the end of theprescribed remedial period of 18months (the “Prescribed RemedialPeriod”). (LR 6.01A and 6.10A)For internal discussion only16
Other highlights of the new delisting regime Effective date: 1 August 2018. Transition period: Companies suspended for more than 12 months before August 2018: 31 July 2019. Companies suspended for less than 12 months before 1 August 2018: 31 January2020. According to the monthly prolonged suspension status report of theHKEx (as at 30 September 2019) 18 suspended companies with PRP expired on 31 July 2019. At least 9 of them were delisted by the HKEx in August and September 2019 underthe new LR6.01A for failure to resume trading by the end of the PRP. 11 suspended companies with PRP expiring on 31 January 2020. 2019. For information, contact Deloitte China.For internal discussion only17
Regulatory landscape 2019. For information, contact Deloitte China.For internal discussion only18
Recent regulatory updates Listed companies governance is one of the top enforcementpriorities for regulators in Hong Kong: 2019. For information, contact Deloitte China.For internal discussion only19
Recent regulatory updatesIt was rare for the SFC to exercise its power to suspend, but this has changed in recent Companies suspended by the SFC-30/03/ 2010: Hontex (0946)Nil.22/08/2012: China High Precision (591)20/12/2013: Qunxing Paper (3868)14/02/2013: China Longevity Group Company Limited (1863)04/12/2014: Sijia Group (1863)15/07/2015: Hanergy (566)15/12/2015: Superb Summit (1228)20/01/2016: Changgang Dunxin Enterprise Company Limited (2229)16/04/2016: Sound Global (967)28/06/2016: Real Gold Mining (246)05/08/2016: National United Resources Holding (254)27/09/2016: Hua Han Health Industry Holdings (587)13/10/2016: China Fiber Optic Network (3777)22/02/2017: GME (8188)04/07/2017: Nationa Agricultural Holdings Limited (1236)08/05/2017: Huishan Dairy (6863)17/05/2017: CG Dunxin (2229)25/05/2017: Tianhe Chemicals (1619)06/06/2017: Lerado Financial Group Company Limited (1225)17/07/2017: China Household Holdings Limited (692)06/10/2017: New Ray Medicine International Holdings Limited (6108)09/11/2017: Tech Pro Technology Development Limited (3823)24/11/2017: First Credit Finance Group Limited (8215)27/11/2017: China Wah Yan Healthcare Limited (648)27/11/2017: Town Health International Medical Group Limited (3886)04/07/2018: Real Nutriceutical Group Limited (2010)20/11/2018: Hua Han Health Industry Holdings Limited (587)08/03/2019: China Ding Yi Feng Holdings Limited (612)29/05/2019: Combest Holdings Limited (8190) 2019. For information, contact Deloitte China.For internal discussion only20
Recent regulatory updates Many listed companies were suspended from trading as aresult of certain issues or regulatory concerns: 2019. For information, contact Deloitte China.For internal discussion only21
Recent regulatory updates HKEx continued to focus on the four Enforcement Themes: 2019. For information, contact Deloitte China.For internal discussion only22
Regulatory environmentAuditorsSFCShareholders RegulatorsHKExWhistle-blowers Creditors onsorsTradingresumedRegulatorsto idationWhite knight Controlling / majorshareholders 2019. For information, contact Deloitte China.CompanyFor internal discussion only23
Seeking a resumption 2019. For information, contact Deloitte China.For internal discussion only24
Seeking a resumption Reasons for suspension Material breaches of the LR Fails to publish financial statements within time limit Fails to maintain sufficient operation or assets Fails to maintain sufficient public float Receives disclaimer or adverse opinion (new suspension rule) Depending on the underlying issues, the regulators will imposedifferent resumption conditions on the company The principle, however, remains the same: no resumption will beallowed unless and until all issues leading to the suspension havebeen properly resolved 2019. For information, contact Deloitte China.For internal discussion only25
Seeking a resumption 3 key categories of suspension casesPN 17 companies/companies with insufficientoperation or assets or infinancial difficultiesCompanies with materialirregularities (accounting/corporate irregularities) Demonstrate that it has abusiness that has substance andis viable and sustainable in thelonger term. Accounting irregularities:discrepancy between groupaccount records and informationobtained by auditors; concernsover authenticity of thedocuments; concerns over thecommercial substance of certainmaterial transactions If due to insufficient operation/assets, acquisition – Note: asuspended issuer that ceased tocarry on the original principalbusiness or to retain anymaterial assets is a listed shelland any acquisition by it will be aRTO and be treated as a newlisting application. If due to financial difficulties,undertake corporate action toresolve the financial difficulties,such as capital reorganization,equity fundraising and a schemeof arrangement. 2019. For information, contact Deloitte China.Companies with insufficientpublic float Devise a plan to restore therequired the minimum publicfloat. Placing of existing shares by thecontrolling or substantialshareholders; or placing of newshares by the issuer. Corporate irregularities: fraud;misappropriation of assets; otherfraudulent activities Address the irregularities: (1)form a IBC; (2) forensicinvestigation; (3) address auditconcerns; (4) audit qualification;(5) internal control review; (6)remedial measures; (7) noconcern about managementintegrity; (8) disclose all materialinformation and publish allfinancial statements.For internal discussion only26
Key criteria for oncernDiscloseinformation tothe marketDemonstrateadequateinternal controlsystemTakeappropriateremedial actionDemonstratethe integrityand competenceof directors 2019. For information, contact Deloitte China.For internal discussion only27
Case studyOld PN 17 company: case study – Grande (186)DateChronology of events30/05/2011-Suspended upon the presentation of creditors’ winding up31/05/2011-Provisional liquidation08/09/2011-Grande was placed in the 1st stage of delisting procedure31/05/2012-A resumption proposal was submitted but was rejected by the HKEx05/07/2012-Grande was placed in the 2nd stage of delisting procedure25/09/2012-Grande requested a review of the Listing Division’s decision to place it in the 2 nd stageof delisting procedure. Review not successful.21/06/2013-A resumption proposal was submitted but was rejected by the HKEx11/07/2013-Grande was placed in the 3rd stage of delisting procedure12/09/2013-A winding up order made against Grande12/02/2014-Grande submitted a resumption proposal to the HKEx29/05/2015-HKEx approved the resumption proposal, and made (among others) the completion ofall transactions contemplated under the resumption proposal as one of theresumption conditions30/05/2016-Fulfilled all resumption conditions and resumed trading 2019. For information, contact Deloitte China.For internal discussion only28
Case study: PN 17 companyResumptionGrande (186) Total current liabilitiesover HKD 3.9 billion Total assets aroundHKD1.3 billion Issues regardingamounts due to relatedcompanies Disclaimer Internal control issues Publication of materialinformation: outstanding financialinformation Internal control review:internal control review, remedial measures, new CFO andCompany Secretary Strengthening existing business:No acquisition, steps taken to strengthen its business Group Reorganization:liquidating certainsubsidiaries: to improve financial position, and to address audit issuesregarding certain subsidiaries. Scheme of arrangement:Bermuda and Hong Kongschemes: discharging of all claims (excluding intercompany debts), by cash andcreditors shares Open offer: 5 offer shares for every 2 shares: raisingSuspensionproceeds of around HKD100 million for the Scheme Capital Reorganization:capital cancellation(unissued), capital reduction (reduce par value), increase authorized sharecapital: remove 1/3 accumulative losses, and enabling Open Offer and Scheme. 2019. For information, contact Deloitte China.For internal discussion only29
Case studyCompanies with material issues: case study – Kaisa (1638)DateLate 2014/early 201508/03/2015-Chronology of eventsThe Company had liquidity issues. Loans defaulted. Many litigations were commencedagainst the Company. CEO resigned.Announced restructuring proposal.31/03/2015-Trading suspended as a result of its failure to publish the 2014 annual 6-Announced that auditors need additional audit evidence on certain matter for its 2014audit.HKEx imposed resumption conditions on the Company, which included, among others,demonstrating sufficient working capital and investigation of matters raised by theCompany’s auditors in the course of the audit.Auditors identified various audit issues. Auditors ceased work. The Company formed anindependent committee to investigate matters.Schemes for restructuring of offshore debts were sanctioned by HK and Cayman court12/07/2016-Offshore debts restructuring became effective.15/07/2016-Auditor resigned and new auditors appointed.19/12/2016-24/03/2017-Forensic accountants published its findings. Recommended action against wrongdoersand remedial steps to be taken.Internal control review completed.26/03/2017-Published the outstanding annual results for 2014 to 201627/03/2017-All resumption conditions fulfilled.Trading resumed. 2019. For information, contact Deloitte China.For internal discussion only30
Case study: material issuesResumptionKaisa (1638) Serious liquidity issues Onshore debts(RMB49.6 billion) Offshore debts (USD2.9billion) Loan default; materiallitigation Material audit issues Publication of theoutstanding financialinformation: New auditors appointed,and published outstanding financial information. Internal control review:internal controlreview, various weaknesses identified and remedial measuresimplemented. Forensic investigation of auditissues: Engage a forensic accountant to investigate audit issues:findings (a) certain former employees were involved in a scheme usingfictitious agreements, substantial improper and unauthorized payments,incorrect accounting and collusion with third parties, to obscure the existenceof certain borrowing agreements; (b) certain payment transactions werewithout clear business purposes or had no identifiable business purposes; (c)certain acquisitions were not properly authorized and approved.Recommended the Company to report the wrongdoing to the authorities andto implement remedial measures.Suspension 2019. For information, contact Deloitte China. Debt restructuring:Restructuring onshore debts by refinancing,restructuring offshore debts by scheme of arrangement: to improve the Company’s financialpositionFor internal discussion only31
Seeking a resumption (Cont.)Example of a company no longer suitable for listing- False and misleading IPO prospectus: Hontex (946)Hontex (946) 2019. For information, contact Deloitte China.-24/12/2009: Hontex was listed on the HKEx-30/03/2010: SFC sought injunction to freezeIPO proceeds , alleging that Hontex materiallyoverstated its turnovers and cash in the IPOprospectus.-20/06/2012: SFC obtained a repurchase order,requiring Hontex to repurchase shares from7,700 public shareholders.-29/10/2012: Repurchase completed – 0.42%public float-22/11/2012: LC decided to delist, on the basisof disclosure of false and misleadinginformation in the IPO prospectus and lack ofpublic float.-23/09/2013: Delisted.For internal discussion only32
Seeking a resumption of trading (Cont.)Initial listing obtained by fraud: China Metal Recycling(773)Facts-22/06/2009: China Metal was listedon the HKEx.-28/01/2013: Trading suspended.-26/07/2013: SFC petitioned to windup the Company on public interestbasis under section 212 of the SFO.SFC alleged that China Metal involvedin a highly complex, sophisticated anddishonest scheme which inflated itsperformance, revenue (over HKD 8billion) and profit (over HKD 1 billion)dating back to the time of its IPOprospectus in 2009.-26/02/2015: Winding up order made.-04/02/2016: Delisted, on the basisthat it obtained its initial listing byfraud. 2019. For information, contact Deloitte China.SFC v. China Metal Recycling (HCCW210/2013)First public interest winding up-Justice Harris: “Although the economicinterests of creditors and minorityshareholders are relevant indetermining a petition such as thepresent, as the authorities to which Ihave referred make clear, theoverarching consideration is thebroader interest of market participantsas a whole. That interest requires thatserious misconduct is subject tounequivocal censure. The appropriateorder in a case where a listing has beenobtained by wholly dishonestfabrication of accounts would, in myview, almost invariably be a winding-uporder”For internal discussion only33
Preparing for investigations A resumption of trading is unlikely to be the end of thematter It usually marks the beginning of investigation by theregulators into the problematic companies and/or theirofficers for past breaches of rules and regulations One of the enforcement objectives: to punishwrongdoers It is important to bear in mind the likelihood ofinvestigations and enforcement actions by theregulators, and to manage the relevant risks asappropriate 2019. For information, contact Deloitte China.For internal discussion only34
Investigations carried out by HKExIssues under Investigations in 1H2019No. of Investigations120100806040200201520162017Main Board12020181H2019GEMNo. of Directors subject toDisciplinary SanctionsDirector's dutiesFailure to cooperate with an Exchange investigation100Inaccurate, incomplete and/or misleading disclosure incorporate communicationFailure to comply with procedural requirements in respect ofnotifiable/connected transactionsRepeated breaches of the Listing Rules8060402002015ED20162017NEDSources: HKEX website 2019. For information, contact Deloitte China.2018INED1H2019Financial reporting - delays, or internal controls and corporategovernance issuesMultiple themesOthersFor internal discussion only35
Investigations carried out by SFC25020015010050013/1414/15Corporate disclosureIntermediary misconduct15/16Corporate misgovernanceMarket manipulation16/1717/18Insider dealingUnlicensed l proceedingsDisciplinary proceedings16/1717/18Maket Misconduct Tribunal proceedingsSources: SFC Annual Report 2017-18 2019. For information, contact Deloitte China.For internal discussion only36
More key takeaways “No Mistake.”“No do-overs.”“Whatever it takes!”“Alright, we have a plan. Six Stones. Three teams. One Shot. Fiveyears ago we lost. All of us. We lost friends. We lost family. We lost apart of ourselves. Today we have a chance to take it all back. Youknow your teams. You know your mission. Get the stones. Get themback. One round trip each. No mistakes. No Do-overs. Most of us aregoing somewhere we know, but that doesn’t mean we should knowwhat to expect. Be careful. Look out for each other. This is the fight ofour lives. We are going to win. Whatever it takes. Good Luck.”Steve Rogers, Avengers: Endgamehttps://youtu.be/nLRnHaf3t54 2019. For information, contact Deloitte China.For internal discussion only37
2019. For information, contact Deloitte China.For internal discussion only38
Juvenia HoJoseph ChuPartner, Hong KongPartner, Hong Kong/ BeijingTel: 852 2852 1018Tel: 852 3919 0505/ 86 10 85884505Email: juveniaho@deloitte.com.hkEmail: Joseph.Chu@simmonssimmons.comJuvenia Ho is a Partner in Deloitte Forensic practice in HongKong. She has over 20 years of experience specializing stigations, litigation support and fraud risk compliancereview throughout Greater China .Juvenia’s extensive forensic accounting experiences includesinvestigation into white collar crime, corruption particularlyin the context of Foreign Corrupt Practices Act and moneylaundering, asset tracing inquiries, bribery & corruption riskassessments.Juvenia’s investigative experiences cover a wide range ofindustries but in particular she has worked extensively in thePharmaceutical, medical device, media & entertainment,gaming, real estate, retail and manufacturing sectors.Juvenia is also experienced in preparing accounting expertreports and exhibits for court hearing, in both civil andcriminal cases for family/estate disputes, share placementsand insider dealing. 2019. For information, contact Deloitte China.Joseph is a partner in the Dispute Resolution Group. Headvises and represents clients in arbitration, banking,general commercial, tax and trust disputes andinvestigations, with a particular focus on internationalarbitration, regulatory investigations and cross-borderlitigation.Joseph joined Simmons & Simmons as a partner in October2013. He was admitted in Hong Kong in 2003, England in2008 and qualified as a lawyer in the PRC in 2012. He is oneof the authors of Sweet & Maxwell’s Arbitration in HongKong: A Practical Guide, 2nd Edition, and was a contributingeditor of Hong Kong Civil Procedure (the “White Book”).Joseph has been recognized as “up and coming” inInternational Arbitration by Chambers Global in 2016. Hehas been described as “best known for his expertiserepresenting Mainland China-based businesses on crossborder arbitrations” and “knowing the Mainland Chinamarket more than most” by Chambers Global. Joseph wasalso identified by the Asian Legal Business in 2016 as one ofthe “Top 15 Rising Lawyers” in the PRC.For internal discussion only39
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Oct 17, 2019 · “The Exchange will normally require suspension of trading in an issuer’s securities if it publishes a preliminary results announcement for a financial year as required under rules 13.49(1) and (2) and the auditor has issued, or has indicated that it will issue, a disclaimerof opinion or
RULE BOOK UPDATED MAY 2019-1 - TABLE OF CONTENTS PAGE RULE 1 Name 2 RULE 2 Objectives 3 RULE 3 Membership 4 RULE 4 Members Entitlements and Obligations 5 RULE 5 Structure 8 RULE 6 Branches 9 RULE 7 Regional Structure 15 RULE 8 National Organisation 19 RULE 9 Officers 26 .
Rule 2. Playing Terms and Definitions Rule 3. Substituting - Coaching - Bench and Field Conduct - Charged Conferences Rule 4. Starting and Ending Game Rule 5. Dead Ball - Suspension of Play Dead Ball Tables Rule 6. Pitching Rule 7. Batting Rule 8. Baserunning Baserunning Awards Table Rule 9. Scoring - Record Keeping Rule 10. Umpiring
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