Jingrui Wangpu plans to go public on the US stock market. The China Securities Regulatory Commission requires supplementary explanations regarding the arrangements or measures for data protection before and after the listing

According to the Zhitong Finance APP, on March 21, the China Securities Regulatory Commission (CSRC) released the "Supplementary Material Requirements for Overseas Issuance and Listing Filing Public Notice (March 14, 2025 - March 20, 2025)." The notice mentioned that Jingrui Wangpu (private placement to public) is required to provide supplementary explanations regarding the main domestic operating entities and their subsidiaries' APPs, mini-programs, and other product situations, including the scale of personal information collection and storage, the usage of personal information, whether there is any data transmission to overseas or provision of personal information to third parties, and to explain the arrangements or measures for information data protection before and after the listing. The company plans to list on NASDAQ with the stock code JRWP.

The CSRC requests the company to supplement the following matters, and asks lawyers to verify and provide clear legal opinions:

1. Please explain: (1) Whether the unpaid capital of the issuer complies with the relevant requirements of the place of registration and listing; (2) The conclusive opinion on the compliance of foreign exchange management, foreign investment, and other regulatory procedures involved in the equity structure setup, as well as whether the foreign investment information reporting obligations have been fulfilled; (3) List and explain the investment time of all indirect shareholders of Zhejiang Jingrui Wangpu, the corresponding shareholding ratio at the issuer level, and explain the reasons for any inconsistencies in shareholding ratios, the risks of control stability and potential defaults that may arise from related arrangements, and the countermeasures; (4) The pricing basis for the equity transfer of Yangxin Hongtai Trading in April 2023 and whether tax declaration has been made for this equity transfer.

2. Please explain: (1) The existence of shareholding on behalf of multiple main domestic operating entities, the reasons for the formation of shareholding on behalf, its evolution, legality and compliance, whether there are disputes or potential disputes, and whether there are any legal regulations prohibiting the holding entities among registered shareholders and actual shareholders; (2) The business scope of multiple domestic operating entities involves market research, please explain whether relevant operations have actually been carried out, and if so, whether relevant qualifications have been obtained.

3. Please explain: In the case where Dongying Yiqun Trading, Zibo Lunsheng Trading, Jinan Zhongyue Shengtai Economic and Trade, and Yangxin Hongtai Trading's business scope does not involve foreign investment access restrictions or prohibited areas, the reasons and necessity for including the relevant enterprises into the issuer's overall structure through agreement control arrangements in February 2024.

4. Please explain: (1) The situation of APPs, mini-programs, public accounts, web pages, and other products operated by the main domestic operating entities and their subsidiaries, including the scale of personal information collection and storage, the usage of personal information, whether there is any data transmission to overseas or provision of personal information to third parties, and to explain the arrangements or measures for information data protection before and after the listing; (2) The specific plans for future value-added telecommunications business, its relevance to the main business, the specific business qualifications required, and the relevant foreign investment access policy regulations.

5. Please explain: Assuming the exercise of the over-allotment option, the number of shares issued, the proportion of total share capital after issuance, the expected amount of funds raised (if any), and list the changes in the equity structure before and after the issuance, as well as whether the controlling shareholder and actual controller have changed after this issuance.

According to the information, Jingrui Wangpu wholesales and retails various electrical products through its operating entities in China. Its products include air conditioners, refrigerators, televisions, washing machines, dryers, and dishwashers