"The First Stock for Hair Loss Treatment" Mandi Inc. (MD) Receives Supplementary Material Request for Overseas Listing Filing, Required to Explain Discrepancies in Controlling Shareholder Identification
Recently, Mandi Inc., a hair loss treatment enterprise, has received a request for supplementary materials from the regulatory authority during the filing process for its overseas issuance and listing. The company is required to provide explanations on matters including the compliance of its offshore structure, existing discrepancies in controlling shareholder identification, complex trustee controller arrangements, and data security, with lawyers conducting verification and issuing clear legal opinions.
In accordance with the requirements, the company must focus on explaining the foreign exchange registration, payment arrangements, pricing fairness, and the fulfillment of tax obligations by relevant transferors involved in the establishment of the offshore structure and round-trip investment, and demonstrate that these are in compliance with the regulatory provisions in effect at the time; it must also elaborate on the pricing basis for acquiring equity in domestic operating entities, payment arrangements, pricing fairness, and the fulfillment of tax obligations by relevant transferors, confirming compliance with the relevant regulations on foreign capital mergers and acquisitions.
Second, it is required to clarify the specific reasons and identification criteria for the inconsistent conclusions on controlling shareholder identification in the filing materials, and issue a clear conclusion on the final identification of the controlling shareholder.
Third, a full penetrating disclosure of the trust arrangements at the upper level of the controlling shareholder must be made, including: the core clauses of the trust or asset management contract (such as specific methods, management authority, fees, term, termination conditions, asset disposal arrangements, etc.), the key time points and methods leading to changes in the actual controller’s rights and interests; combined with the specific clauses of the trust deed, it is necessary to elaborate on the rights and obligations of each party to the trust (such as settlor, trustee, beneficiary, protector, etc.), and fully disclose the specific information of all trust beneficiaries, including the beneficiaries’identities, beneficial shares, and their relationship with the settlor of the trust.
Fourth, it is required to explain the development and operation of websites, mini-programs, apps and other products by the company and its subsidiaries, whether information is provided to third parties, the types of information and security protection measures, and disclose the scale of user information, data usage, and data security arrangements before and after the listing.
Fifth, it is necessary to issue a clear concluding opinion on whether the business scope and actual operations of the company’s domestic operating entities involve restricted or prohibited fields for foreign investment.
NewTimeSpace Disclaimer: All content herein is the original work of NewTimeSpace. Any reproduction, reprinting, or use of this content in any other manner must clearly indicate the source as "NewTimeSpace". NewTimeSpace and its authorized third-party information providers strive to ensure the accuracy and reliability of the data, but do not guarantee the absolute correctness thereof. This content is for reference only and does not constitute any investment advice. All transaction risks shall be borne by the user.
