Chapter 4

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Question:

As from 1 October 2019 (“Effective Date”), the amendments to the Financial Reporting Council Ordinance (Cap. 588) (“FRCO”) took effect and the Financial Reporting Council (“FRC”) became Hong Kong’s independent regulator of listed entity auditors.

After the Effective Date, all audit firms intending to carry out a PIE Engagement are subject to a system of registration (for Hong Kong audit firms) and recognition (for non-Hong Kong audit firms) as PIE Auditors.

Any non-Hong Kong audit firm is required to be recognized by the FRC before the audit firm can (i) “undertake” (i.e. accept an appointment to carry out) any PIE Engagement; and (ii) carry out any PIE Engagement for an overseas entity. Under the FRCO, the Exchange needs to issue a Statement of No Objection (“SNO”) before the FRC considers an application of the overseas audit firm to be recognized as a Recognized PIE Auditor. The overseas audit firm must not accept an appointment for carrying out any PIE Engagement for an overseas entity unless the application for recognition has been granted.

(i) Which types of engagements fall within the PIE Engagements?
(ii) On the appointment of a non-Hong Kong audit firm for the PIE Engagement, who should submit the formal application to the FRC?

Answer:

(i) In relation to equity issuers and applicants, the audit engagements falling within the PIE Engagements are summarized below:
 
Preparation of auditors’ or accountants’ report Is it a PIE Engagement?
Annual financial statements
Listing document
Very substantial acquisition
Reverse takeover
Major transaction ×
Very substantial disposal ×
Extreme transaction ×
De-SPAC transaction ×

For those engagements not falling within the PIE Engagements, such as accountants’ reports included in major transaction and very substantial disposal circulars, the Listing Rules continue to apply after the Effective Date. Therefore, it is at the Exchange’s discretion to accept an overseas audit firm as the reporting accountant under the Listing Rules and recognition with the FRC is not required.
(ii) The FRC considers the recognition application of a non-Hong Kong audit firm on a case-by-case basis. Therefore, the application should be submitted by the overseas entity. Please see the table below:
 
Location of audit firm Application should be submitted by
Overseas audit firm Overseas entity,
together with a SNO issued by the Exchange
Endorsed Mainland audit firm Not applicable.
(Endorsed Mainland audit firms are recognized as a PIE Auditors without a recognition application being made to the FRC.)
Notes:
1. A public interest entity (PIE) is either (a) a listed corporation whose listed securities comprise at least shares or stocks; or (b) a listed collective investment scheme. Therefore, an entity with only listed debts without listed shares or stocks is not a PIE.
2. For further details on the recognition of overseas audit firms, please refer to the FRC’s website.

FAQ No. 059-2019
LR reference: Main Board Rules 4.03, 19.20, 19C.16 / GEM Rules 7.02, 24.13
Released on 06/09/2019 (Updated in January 2022)

Question:

The overseas equity issuer or applicant must seek a SNO from the Exchange to engage an overseas audit firm to undertake its PIE Engagements. After the SNO is obtained, that issuer or applicant can submit the recognition application to FRC.

What are the assessment criteria to be considered by the Exchange for the issue of a SNO?

Answer:

SNO is granted on by a case-by-case basis.

As set out in note 2 to Main Board Rule 4.03(1) (note 2 to GEM Rule 7.02(1)), we will issue a SNO if the overseas audit firm:

(a) has an international name and reputation;
(b) is a member of a recognized body of accountants; and
(c) is subject to independent oversight by a regulatory body of a jurisdiction that is a full signatory to the IOSCO MMOU. It would be acceptable if the relevant audit oversight body is not a signatory to the IOSCO MMOU but the securities regulator in the same jurisdiction is a full signatory to the IOSCO MMOU.

In this regard, the overseas equity issuers and applicants are reminded that they should plan their application ahead and allow sufficient time for them to seek the SNO and obtain the FRC’s approval for recognition of a Recognized PIE Auditor.

FAQ No. 060-2019
LR reference: Main Board Rules 4.03, 19.20, 19C.16 / GEM Rules 7.02, 24.13
Released on 06/09/2019 (Updated in January 2022)

Question:

What information should be submitted to the Exchange when making an application for a SNO?

Answer:

The SNO application must be made in writing. Based on all relevant facts and circumstances, the overseas equity issuer or applicant should provide an explanation, that supports the SNO application, and all other relevant information that it reasonably believes should be brought to the Exchange’s attention, including but not limited to:

(1) Details of the PIE Engagement (see FAQ No. 059-2019) and role of the overseas audit firm acting as:
a. auditors; and/or
b. reporting accountants.
(2) Information of the issuer or the applicant or the business, company or companies being acquired (collectively “target” in the case of an acquisition), including its name, address, place of incorporation and nature of the business of the group/target.
(3) Information of the overseas audit firm, including:
a. having an international name and reputation;
b. being a member of, or registered with, an accountancy body (please specify the name of accountancy body in the home country) that is a member of the International Federation of Accountants (IFAC) (see note 1 below); and
c. being subject to independent oversight by a regulatory body of a jurisdiction (please specify the name of regulatory body in the home country) that is a signatory to the IOSCO MMOU (see note 2 below).
(4) Auditing and financial reporting standards adopted in relation to the PIE Engagement.
(5) Reasons of why an overseas audit firm is needed to undertake the PIE Engagement (see note 3 below), such as:
a. the overseas audit firm has a geographical proximity and familiarity with the businesses of that overseas applicant or issuer or the target; and/or
b. that overseas applicant or issuer or the target is listed on a Recognised Stock Exchange (as defined in Rule 1.01), and the overseas audit firm is the auditor of that overseas applicant or issuer or the target; and/or
c. the overseas audit firm is the statutory auditor of that overseas applicant or issuer or the target.

Note 1: A SNO issued by the Exchange is one of the eligibility criteria to be a Recognized PIE Auditor. There is no indication that the overseas audit firm mentioned in the SNO will be approved by the FRC, as the FRC has the following additional criteria:

(a) the overseas audit firm is subject to the regulation of an overseas regulatory organization recognized by the FRC; and
(b) the overseas audit firm has adequate resources and possesses the capability to carry out a PIE Engagement for the overseas entity.

Generally, an overseas regulatory organization is recognized by the FRC, if it is a member of the International Forum of Independent Audit Regulators (IFIAR); or from a jurisdiction which has attained equivalence status granted by the European Commission under Article 46 of the Statutory Audit Directive 2006/43/EC. For details, please refer to the FRC’s website.

Note 2: It would be acceptable if the relevant audit oversight body is not a signatory to the IOSCO MMOU but the securities regulator in the same jurisdiction is a full signatory to the IOSCO MMOU.

Note 3: The Exchange will consider exercising its discretion not to issue a SNO if the overseas issuer or applicant fails to satisfy the Exchange of its reasons for its engagement of an overseas audit firm to undertake the PIE Engagement.

FAQ No. 061-2019
LR reference: Main Board Rules 4.03, 19.20, 19C.16 / GEM Rules 7.02, 24.13
Released on 06/09/2019 (Updated in January 2022)

Question:

Main Board Rule 4.03 (GEM Rule 7.02) requires the reporting accountants to be normally qualified under the Professional Accountants Ordinance (Cap. 50).

After the amendments to the FRCO became effective, is the overseas equity issuer or applicant still required to apply the waiver of Main Board Rule 4.03 (GEM Rule 7.02), in addition to seeking the SNO, when it proposes to appoint an overseas audit firm to act as a reporting accountant for its PIE Engagement?
 

Answer:

Yes. After the Effective Date, the overseas equity issuer or applicant is still required to apply for this waiver to the Exchange together with its SNO application.

We will grant this waiver subject to the overseas audit firm to be recognized by the FRC. The issuer or applicant should also disclose this waiver (including details and reasons) in its circular or listing document.

FAQ No. 063-2019
LR reference: Main Board Rule 4.03 / GEM Rule 7.02
Released on 06/09/2019 (Updated in January 2022)

Question:

Is an overseas equity issuer required to apply a “new” SNO in the following circumstances:

(i) Annual renewal of the recognition (i.e. “same” overseas audit firm) to the FRC?
(ii) To appoint an overseas audit firm (who is the auditors of the issuer) as its reporting accountants for a transaction circular, which falls within the PIE Engagements?
(iii) To appoint “another” overseas audit firm as its auditors or reporting accountants for a transaction circular (which falls within the PIE Engagements)?

Answer:

In the circumstances described:

(i) No. The SNO is not required when applying for renewal of the recognition to the FRC.
(ii) No. The SNO is not required. In addition, the issuer does not have to re-apply for recognition to the FRC when the recognition of that audit firm remains valid.
(iii) Yes. The issuer should make a fresh recognition application, together with the SNO, to the FRC.

FAQ No. 065-2019
LR reference: Main Board Rules 4.03, 19.20, 19C.16 / GEM Rules 7.02, 24.13
Released on 06/09/2019 (Updated in January 2022)

Question:

Does an overseas equity issuer or applicant need to disclose the fact that its auditors or reporting accountants for a PIE Engagement are the Registered or Recognized PIE Auditors in the annual report, circular or listing document?

Answer:

Yes. It should disclose that fact.

FAQ No. 066-2019
LR reference: Main Board Rules 4.03, 19.20, 19C.16 / GEM Rules 7.02, 24.13
Released on 06/09/2019 (Updated in January 2022)

Question:

Does an overseas equity applicant need to disclose the name of the auditors after listing in the listing document?

Answer:

Yes. For clarity, the overseas applicant should disclose the name of its auditors after listing at the time of the publication of the listing document.

In case where an overseas applicant engaged a Hong Kong audit firm to act as its reporting accountant for preparing the accountants’ report in its listing document, but it intends to appoint an overseas audit firm as its auditors after listing, it should seek a SNO from the Exchange and submit a recognition application to the FRC. At the time of the publication of the listing document, if its application is under the FRC’s consideration, that fact should be disclosed.

FAQ No. 067-2019
LR reference: Main Board Rules 4.03, 19.20, 19C.16 / GEM Rules 7.02, 24.13
Released on 06/09/2019 (Updated in January 2022)

Question:

Is an equity issuer incorporated in the PRC (“PRC issuer”) permitted to appoint an overseas audit firm as its reporting accountant for the preparation of the accountants’ report in a notifiable transaction circular relating to the acquisition of an overseas company (regardless of whether it constitutes a PIE Engagement)?

Answer:

Yes. The PRC issuer is permitted to appoint an overseas audit firm to carry out an engagement in relation to the acquisition of an overseas company, provided that the PRC issuer seeks a waiver from strict compliance with Main Board Rule 4.03 (GEM Rule 7.02), and obtains a SNO (in the case of PIE Engagements) from the Exchange.

FAQ No. 076-2022
LR reference: Main Board Rules 4.03, 19A.08 / GEM Rule 7.02
Released on 01/01/2022

Question:

The relevant Rules requires, among other things, the ageing analysis be presented on the basis of the date of the relevant invoice or demand note.

For issuers in industries that do not issue invoices to their customers, but have sales and purchase contracts with its customers which set out the agreed payment schedule, how should they present their ageing analysis of accounts receivable and accounts payable?

Answer:

These issuers should present the ageing analysis based on the payment schedule set out in the sales and purchase contracts.

FAQ Series 31, FAQ No. 7
LR reference: Main Board Rules 4.05(2)(a) and (b), Note 2 to Rule 4.05(2), paragraph 4(2)(a) and (b) of Appendix 16, Note 4.2 of Appendix 16 / GEM Rules 7.04(2)(a) and (b), Note 2 to Rule 7.04(2), Rules 18.50B(2)(a) and (b), Note to Rule 18.50B(2)
Released on 6/2/2015 (Updated in February 2020)

Question:

In a VSD, Listco proposes to sell its interest in a company acquired two years ago. Can Listco include, in the circular, the company's financial information from the acquisition date?

Answer:

The circular should contain the company's financial information for at least three financial years.

FAQ Series 11, FAQ No. 5
LR reference: Main Board Rules 14.68(2)(a)(i), 4.06(1)(a) note / GEM Rules 19.68(2)(a)(i), 7.05(1)(a) note
Released on 20/5/2010

Question:

Whether the Exchange will allow an applicant, including a biotech company, to adopt generally accepted accounting principles in the United States (US GAAP) in the preparation of accountants' report and subsequent financial reports after listing?

Answer:

Rule 4.11 requires an accountants' report in a listing document be prepared in Hong Kong Financial Reporting Standards or International Financial Reporting Standards (IFRS) for non-PRC companies.

US GAAP is acceptable for an overseas issuer with, or seeking, a dual primary or secondary listing in the U.S. and on the Exchange (paragraph 29 of Guidance Letter HKEX-GL111-22).

An applicant already listed in U.S. may apply for a waiver from Rule 4.11 and note 2.1 to paragraph 2 of the Appendix 16 to use US GAAP in the preparation of an accountant's report in its prospectus and the financial statements issued after listing.

In considering whether to grant the waiver, the Exchange will take into account the following:

(i) the applicant's place of operation is in the U.S., and whether it has been adopting US GAAP;
(ii) whether the adoption of US GAAP enables its investors to make a more meaningful comparison of its performance with its peers;
(iii) the comparability between US GAAP and IFRS; and
(iv) whether there is any material difference between the financial statements prepared using US GAAP and IFRS.

Please refer to Guidance Letter HKEX-GL102-19 for the details of the conditions, at a minimum, required by the Exchange on granting such waiver.

Secondary listed issuers that are listed in the US and new secondary listing applications from US-listed applicants should refer to Guidance Letter HKEX-GL111-22 for the transitional arrangements on the use of US GAAP for secondary listing.

FAQ Series N/A, FAQ No. 034-2018
LR reference: Main Board Rules 4.10, 4.11, 19.13, 19.14, 19.25A, 19C.10D, 19C.23 / GEM Rules 7.12, 7.14, 24.18A
Released on 24/8/2018 (Updated on 01/01/2022)

Question:

Where and for how long should documents on display be published online?

How will these documents be removed from the relevant websites after the expiry of the prescribed display period?

Answer:

Issuers should publish documents on display on both the HKEX website (through EPS under the new headline category “Documents on Display”) and the issuer’s website.

For documents that are published to meet transaction disclosure obligations only, issuers are required to publish them for time period prescribed by the Listing Rules (which is the same as what the Listing Rules originally require for physical display of such documents).

For documents that are published to meet ongoing disclosure obligations (e.g. constitutional documents, audited financial information and previous transaction circulars), these should be published on a continuous basis. There is no time limit on the length of time listing documents should remain online. (Note: These documents are already published online on a continuous basis. Issuers will not have to publish them again to meet any transaction disclosure obligations as such obligations will be removed with the changes to the Listing Rules.)

After the expiry of any relevant display period prescribed by the Listing Rules, issuers should remove the documents on display manually from the EPS themselves and can also remove them from their own website. They should not do so before the expiry of the relevant display period. The Exchange will not automatically remove documents of display from EPS after a relevant display period has expired.

FAQ Series N/A, FAQ No. 075-2021
LR reference: Main Board Rules 4.14, 5.01B(1)(b), 5.02B(2)(b), 14.66(10), 14.67A(2)(b)(viii), 14A.70(13), 15A.21(4), 17.02(2), 19.10(5)(e) and (6), 19A.27(4), 19A.50, 19C.10B, 29.09, 29.10, 36.08(3), Appendix 1A paragraph 53, Appendix 1B paragraph 43, Appendix 1C paragraph 54, Appendix 1D paragraph 27, Appendix 1E paragraph 76, Appendix 1F paragraph 66, Appendix 4 paragraph 9(b), Appendix 7H paragraphs 5 and 15, Appendix 24 / GEM Rules 7.18, 8.01B(1)(b), 8.02B(2)(b), 19.66(11), 19.67A(2), 20.68(13), 23.02(2), 24.09(2), (3), (5)(a),(e) and (6), 25.20(4), 25.37, 32.05(3), 35.10, 35.11, Appendix 1A paragraph 52, Appendix 1B paragraph 42, Appendix 1C paragraph 53, Appendix 4 paragraph 9, Appendix 17
Released on 18/6/2021 (Updated on 01/01/2022)

Question:

(i) Given the Exchange has now updated the audit terminology in the Rules with reference to the revised HKSAs on auditor reporting, the terms “modified opinion” and “modified report” are defined in Main Board Rule 1.01/ GEM Rule 1.01. However, there is no definition of “modification” in the Rules.

Please clarify the use of the term “modification”.
(ii) Where the financial information has been reviewed and a review conclusion has been expressed by the auditors/ reporting accountants (e.g. FAQ 004-2017), what is meant by “modification” referred to in the Rules, interpretation and guidance issued by the Exchange?

Please clarify the use of the term “modification” in that context.

Answer:

(i) “Modification” is a generic term which should be read in the context of the Rule.

Audit engagements

The terms “modified opinion” and “modified report” defined in Main Board Rule 1.01/ GEM Rule 1.01 relate to an accountants’ report or auditors’ report containing an audit opinion.

Where a Rule explicitly refers to a “modified opinion”, then the term “modification” should be read in the context of that Rule and should refer to a “modified opinion”.

The same applies when a Rule explicitly refers to a “modified report”, then the term “modification” should be read in the context of that Rule and should refer to a “modified report”.

For reference, the table below summarises the terminologies used in the current Rules and the HKSAs:
 
  Terminology used
Meanings Current Rules HKSAs

Matters that affect the audit opinion:
 -  qualified opinion
 -  adverse opinion
 -  disclaimer of opinion

Modified
opinion
Modified
opinion

Matters that affect the audit opinion:
 -  qualified opinion
 -  adverse opinion
 -  disclaimer of opinion

AND/OR

Matters that do not affect the audit opinion:
 -  emphasis of matter
 -  material uncertainty related to going concern

Modified report No specific
equivalent term
(ii) Where the financial information has been reviewed and a review conclusion has been expressed by the auditors/ reporting accountants, then the term “modification” in the Rules and FAQs should refer to:

Review engagements
(a) a modified review conclusion (i.e. qualified conclusion, an adverse conclusion or a disclaimer of conclusion); and/or
(b) an emphasis of matter paragraph or a paragraph to highlight a material uncertainty related to going concern without modifying the review conclusion.
(Note: A review is substantially less in scope than an audit conducted in accordance with relevant HKICPA standards (or equivalent standards issued by IAASB and China Ministry of Finance). Currently, the applicable HKICPA standards for a review engagement are Hong Kong Standards on Review Engagements 2400 (Revised) and 2410.)
 

FAQ 053-2019
LR reference: Main Board Rules 
1.01, 4.18, 14.68(2)(a)(i), Appendix 1A Paragraph 35, Appendix 1C Paragraph 42(2), Appendix 1E Paragraph 35, Appendix 16 Paragraphs 45(7) and 46(8)/ GEM Rules 1.017.22, 18.50(8), 18.64, 18.76, 19.68(2)(a)(i), Appendix 1A Paragraph 35, Appendix 1C Paragraph 42(2)
Released on 1/3/2019

Question:

What are the disclosure requirements under Section 436 of the New Companies Ordinance for a Hong Kong incorporated issuer in relation to the publication of non-statutory accounts in its:

(a) Annual/interim results announcement; and
(b) interim report, quarterly results announcement / financial report, circulars or listing documents?

Answer:

The issuer must include a statement indicating that the statement of comprehensive income for a full financial year and/or the statement of financial position at a financial year end (the "Statements") presented in the account are not statutory financial statements under the New Companies Ordinance. The issuer must also disclose whether (i) an auditor's report had been prepared; and (ii) the auditors gave a qualified or modified audit opinion on the Statements.

For details, please refer to Accounting Bulletin 6 "Guidance on the Requirements of Section 436 of the Hong Kong Companies Ordinance Cap.622" issued by Hong Kong Institute of Certified Public Accountants at: https://www.hkicpa.org.hk/-/media/HKICPA-Website/Members-Handbook/volumeII/ab6.pdf

FAQ Series 31, FAQ No. 13
LR reference: Main Board Rules 13.48, 13.49(1), 13.49(6), 14.66 to 14.69, 11.03 & 11.04, 11.16 to 11.19, 14.61 & 14.62, 4.25 to 4.29 / GEM Rules 18.49, 18.53, 18.66, 18.78, 18.79, 19.66 to 19.69, 14.03 & 14.06, 14.29 to 14.31, 19.61 & 19.62, 7.27 to 7.31
Released on 11/9/2015 (Updated the hyperlink to Accounting Bulletin 6 in October 2019) (Updated in February 2020)

Question:

A listed issuer proposes to place new shares to independent third parties for cash consideration, details of which will be disclosed by way of an announcement as required under Main Board Rule 13.28 / GEM Rule 17.30.

Where the listed issuer provides information about the impact of the proposed placing on its financial position, is it required to comply with Main Board Rule 4.29 / GEM Rule 7.31 if the announcement contains the following information?

(a) The adjusted net asset value of the listed issuer group calculated based on the net proceeds from the proposed placing and its latest published consolidated net asset value.
(b) A qualitative explanation of the effect of the proposed placing on its financial position (for example, the proposed placing would increase the net asset value of the listed issuer group).

Answer:

Main Board Rule 4.29 / GEM Rule 7.31 sets out the standards of preparation and assurance associated with any disclosure of pro forma financial information (whether mandatory or voluntary) in any documents issued by the listed issuer under the Listing Rules. This requirement would therefore apply to announcements of the listed issuer.

In the present case, the "adjusted net asset value" described in scenario (a) is regarded as pro forma financial information subject to Main Board Rule 4.29 / GEM Rule 7.31.

In scenario (b), while a qualitative explanation of the effect of the proposed placing on the listed issuer financial position is not subject to Main Board Rule 4.29 / GEM Rule 7.31, the listed issuer must ensure that information contained in the announcement is accurate and complete in all material respects and not misleading or deceptive under Main Board Rule 2.13 / GEM Rule 17.56.

FAQ Series 7, FAQ No. 68
LR reference: Main Board Rules 4.29 / GEM Rules 7.31
Released on 28/11/2008

Question:

What are the accounting and auditing related requirements applicable to an overseas issuer?

Answer:

Qualification requirements for auditors and reporting accountants

Where the preparation of an accountants’ report constitutes a PIE Engagement under the Financial Reporting Council Ordinance (“FRCO”), the issuer must normally appoint a firm of practising accountants that is qualified under the Professional Accountants Ordinance and is a Registered PIE Auditor under the FRCO.

An overseas issuer is permitted to appoint an overseas audit firm as its reporting accountant for the preparation of the accountants’ report, provided that the overseas issuer seeks a waiver from strict compliance with Main Board Rule 4.03 (GEM Rule 7.02), and obtains a Statement of No Objection (“SNO”) (in case of a PIE Engagement) from the Exchange.

An overseas audit firm is required to be recognised by the FRC before the audit firm can: (a) “undertake” (i.e. accept an appointment to carry out) any PIE Engagement; and (b) carry out any PIE Engagement for an overseas issuer. An issuer is required to apply to the Exchange for, and the Exchange is required to issue, a SNO before the FRC considers an application to recognise an overseas audit firm. The Exchange grants the SNO on a case by case basis.

For details of the SNO application (including the auditor after listing), please refer to “Frequently asked questions on recognition of overseas audit firms in relation to the amendments to the Financial Reporting Council Ordinance – Effective on 1 October 2019” (FAQ No. 059-2019 to 067-2019).

Preparation of reconciliation statement

Where the Exchange allows an accountants’ report or annual financial statements to be drawn up otherwise than in conformity with HKFRS or IFRS, the accountants’ report or annual financial statements will be required to conform with financial reporting standards acceptable to the Exchange. In such cases the Exchange will normally require the accountants’ report or, as the case may be, the annual financial statements, to contain a reconciliation statement setting out the financial effect of the material differences (if any) from either HKFRS or IFRS.

For US-listed secondary listing applicants, the requirement for the preparation of a reconciliation statement in respect of the accountants’ report prepared under US GAAP in a listing document applies to listing applications submitted on or after 1 January 2023.

For US-listed issuers with a secondary listing on the Exchange that adopted US GAAP in the preparation of their financial statements, the requirement for the preparation of a reconciliation statement applies to the first annual financial statements for the financial year commencing on or after 1 January 2022 and subsequent interim and annual financial statements.

For details, please refer to Section F of the Guidance Letter on the guidance for overseas issuers (HKEX-GL111-22).

Requirement to convert to HKFRS or IFRS upon de-listing

An overseas issuer with a dual primary or secondary listing that adopts one of the alternative overseas financial reporting standards (other than issuers incorporated in a member state of the European Union which have adopted EU-IFRS) for the preparation of its annual financial statements must adopt HKFRS or IFRS if it de-lists from the jurisdiction of that alternative overseas financial reporting standards and must do so for any annual and interim financial statements (and quarterly financial statements for GEM issuer only) that fall due under the Listing Rules, and are published, after the first anniversary of the date of its de-listing.

FAQ Series 25, FAQ No. 20
LR reference: Main Board Rules 4.03, 19.14, Note 4 to 19.14, 19.20, 19.25A, 19C.10D, Note 4 to 19C.10D, 19C.16, 19C.23, Note 4 to 19C.23 and Note 4 to 19.25A / GEM Rules 7.02, 7.14, Note 4 to 7.14, 24.13 and Note 4 to 24.18A
Released on 01/01/2022