Biya International Group (BIYA.US) plans to list on NASDAQ. The China Securities Regulatory Commission requires an explanation of the equity structure and any changes in equity ownership.

On November 10th, the International Department of the China Securities Regulatory Commission (CSRC) released supplementary filing requirements for overseas issuance and listing (from November 3rd, 2023 to November 9th, 2023). Among them, supplementary materials were requested from Biya International Group to explain the equity structure and changes in equity ownership, as well as the situation of participating and controlling companies. It is reported that Biya International Group (BIYA.US) publicly disclosed its prospectus for listing on NASDAQ on October 31st, 2023. The announcement shows that the CSRC has requested Biya International Group to provide supplementary explanations on the following matters, and to have lawyers verify and provide clear legal opinions: 1. Regarding the equity structure and changes in equity ownership, please explain the pricing basis, rationality, and compliance with tax obligations of the three equity transfers of Shenzhen Gongwu Park Network during the period from 2021 to 2023. 2. Regarding the situation of participating and controlling companies, (1) it is required to explain whether the fact that multiple domestic operating entities of your company have actually engaged in relevant businesses without obtaining relevant qualifications in value-added telecommunications, human resources services, labor dispatch, etc. constitutes a substantial obstacle to this issuance and listing; (2) it is required to explain the rectification and standardization of the establishment of five branch companies by Dongguan Gongwu Park Yifang, the main domestic operating entity, without making written reports and filings to the relevant competent authorities in accordance with the "Provisional Regulations on the Labor Market for Human Resources" and other relevant regulations, and whether this situation constitutes a substantial obstacle to this issuance and listing. 3. Regarding standardized operations, please explain the situation of products such as APP, mini-programs, official accounts, web pages, software systems operated by domestic operating entities and subsidiaries, including the scale of collection and storage of personal information, the use of personal information, whether there is a situation of transferring data overseas or providing personal information to third parties, and explain the arrangements or measures for information and data protection before and after listing. 4. Regarding the issuance and listing plan, (1) please explain the issuance method, issuing objects, the proportion of the total share capital after issuance, and the changes in equity structure before and after the issuance, as well as whether the controlling shareholder and actual controller have changed after this issuance; (2) please explain the specific circumstances of using the raised funds for compensation to underwriters. According to the information disclosed by the CSRC, Biya International Group's filing type is an indirect overseas listing, and the filing applicant is Shenzhen Gongwu Park Network Technology Co., Ltd., with a filing acceptance date of October 27th, 2023. Revere Securities LLC is its underwriter, and Jingtian & Gongcheng is its domestic lawyer. According to the information, the filing applicant Gongwu Park is an internet company engaged in building a blue-collar labor resource sharing platform. It independently built the Gongwu Park platform, a human resource sharing platform focused on blue-collar labor. Through innovative guarantee transaction models, it solves the needs and problems of enterprises, human resource companies, and blue-collar job seekers, with services covering more than 5 provinces and 30 cities.