Infrawaves: CSRC seeks supplementary filing materials on nominee holdings and 5% look-through on Suzhou Guangyue

NewTimeSpace News: On October 23, 2026, the International Cooperation Department of the CSRC disclosed the supplementary materials requirements for overseas offering and listing filing issued to four companies for the period from October 19 to 23, including Infrawaves Co., Ltd., which must provide supplementary explanations on seven aspects, with its lawyers to verify and issue clear legal opinions.

The inquiry requires an explanation of whether nominee shareholding exists in the Company's history, together with conclusive opinions on the legality and compliance of its establishment and past equity changes; an explanation of whether the industrial and commercial registration changes of the partnership enterprises Jiliu Xiliu and Jiliu Xize have been completed and whether there are any changes compared with the filing materials; an explanation of whether Xinglian Dingsen and Hangzhou Guanghe are filed private funds and, if not, look-through verification in accordance with Guideline No. 2; and it notes that Hangzhou Guanghe and Suzhou Guangyue are controlled by the same entity, so their shareholdings should be aggregated and Suzhou Guangyue should undergo look-through verification under the standard for 5%-plus shareholders.

The inquiry further requires a transaction-by-transaction explanation, in chronological order, of the transaction prices and pricing basis of shareholders newly added in the past 12 months (including existing shareholders that newly acquired shares), with conclusive opinions on the reasons for differences in subscription prices, their fairness and reasonableness, and whether any benefit transfer exists; verification of whether the newly added shareholders Yuanchuang Future Fund and Huahai Jinpu involve circumstances where entities prohibited by laws and regulations from holding shares directly or indirectly hold shares in the Company; an explanation of whether the relationship between newly added shareholders such as Shanghai Guofang and the sponsor of this offering affects the independence of intermediaries and complies with the rules of the listing venue; and explanations on matters including the setup of multiple employee shareholding platforms, whether Jiao Fangzheng's service of less than one year meets the conditions for equity incentive grants, the progress of the state-owned shareholder Karamay Chengfa Fund in obtaining the state-owned share designation, and the consistency of the maximum offering size between the filing materials and the prospectus.