The US Securities and Exchange Commission (SEC) Division of Corporation Finance published CF Disclosure Topic No. 10 (the disclosure topic) on November 23, 2020. The disclosure topic provides guidance to China-based Issuers: companies based in or with the majority of their operations in the People’s Republic of China (China). The guidance is the latest step by US regulators to strengthen investor protection with respect to China-based Issuers, particularly with regards to the unique legal and regulatory risks such companies present. The guidance follows the recommendations of the President’s Working Group on Financial Markets, and shows that US regulators remain focused on China-based Issuers that do not comply with US investor protection laws.
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