EUR 93.41 For Business Accounts Only

China ADRs Delisting

On 2nd Dec 2021, Securities Exchange Commission (SEC) issued Final amendments to implement the Holding Foreign Companies Accountable Act (HFCAA).

On 24th Mar 2021, SEC had issued Amendments, Seeks Public Comment on HFCAA. This was a follow up on the HFCAA which was signed by Trump on 18th Dec 2020 and which seeks to stop China ADRs from being traded on the US exchanges.

We have covered the background in our previous notes:
China ADRs Secondary Listing Deep-Dive: Yin and Yang, published in Feb 2020, we looked at the background and rules around undertaking a secondary listing in Hong Kong and then came up with a short-list of companies that might undertake a secondary listing.

In China ADRs Secondary Listing: COVID-19 Has Increased the Tension but Narrowed the Short List published in May 2020, we looked at the recent developments and provided a revised short-list.

In China ADRs Secondary Listing - Holding Foreign Companies Accountable Act - I’m Coming Home, published in May 2020, we spoke about the implication of the act which had made its way through the senate.

In China ADRs Secondary Listing - Pipeline looks rich, have three years to move, published in Feb 2021, and China ADRs - SEC Notice - Instead of Three, Probably Have Four Years till 2025 - Correction Overdone we provided an update on HFCAA and looked at some of the ADRs which could be next to undertake a secondary listing in Hong Kong.

In this note, we'll talk about the final amendments and its possible timelines and implications.