The China Securities Regulatory Commission has released supplementary material requirements for the overseas listing filing of Yunhui Algorithm, including equity structure and standardized operations, among others.

On September 28th, the China Securities Regulatory Commission (CSRC) announced the supplementary material requirements for overseas issuance and listing registration (September 22nd, 2023 to September 28th, 2023). Among them, Yunhui Suan is required to provide additional explanations on the following issues and ask lawyers to verify and provide clear legal opinions: 1. Regarding the equity structure, please explain: (1) the reasons and rationality and compliance of including Shenzhen Yunhui Suan, a participating company, in the consolidated financial statements, and whether there are other controlling arrangements such as agreements; (2) the reasons and compliance of insufficient registered capital of the domestic operating entity, and whether it has a significant impact on the company's operation and debt-paying ability. 2. Regarding equity changes, please explain the pricing basis, fairness, and payment of taxes for the zero-dollar acquisitions of Qingdao Yunhui Suan's equity by Yunhui Suan Information Technology and the zero-dollar acquisitions of Shenzhen Yunhui Suan's equity by Dai Shengwei. 3. Regarding standardized operations, please explain: (1) whether the operating scope of the domestic main operating entity involves prohibited or restricted areas for foreign investment, further self-examination, and provide clear basis for compliance with the "Special Management Measures for the Access of Foreign Investment (Negative List)" (2021 Edition); (2) regarding payment services involved by the company, please explain the scale of relevant payment business during the reporting period, the proportion of fees collected to the company's revenue, whether it has obtained the qualifications for payment business licenses, if not obtained, whether it constitutes operating without a license, and whether it constitutes a substantive obstacle to this issuance and listing; (3) for websites, apps, mini-programs, and other products developed and used by the company, provide information on the scale of customer information collected and stored, the use of data, whether it involves providing personal user information to third parties, and arrangements or measures for personal information protection and data security before and after listing. 4. Regarding the issuance plan, please explain the specific plan for this issuance and listing, including the expected amount of funds to be raised, issuance methods, issuance objects, etc., list the changes in equity structure before and after the issuance, and explain the compliance of issuing securities to underwriters and whether there are any situations of benefit transfer. According to the information publicly available, Yunhui Suan plans to list on the US Nasdaq Exchange, or may have already submitted a confidential filing. Public information shows that Yunhui Suan, based on the "sharing economy and innovation," focuses on the flexible employment field and is a crowdsourcing service platform that helps companies reduce labor costs and provides flexible job choices for freelancers. Currently, Yunhui Suan has strategically cooperated with over 1000 companies and provided gig services to nearly one million flexible employees. It has also established subsidiaries in dozens of provinces and cities nationwide.