Cai Fu Zai Xian·2026-01-09 02:51Core Viewpoint - The Shenzhen Stock Exchange has issued multiple penalties related to the convertible bond project of Sichuan Medical Technology Co., Ltd. (300078), highlighting issues of non-operational fund occupation and information disclosure violations by major shareholders and related parties [1] Group 1: Penalties and Disciplinary Actions - Sichuan Medical Technology and related parties received disciplinary actions from the Shenzhen Stock Exchange due to violations, including a public reprimand [1] - Citic Securities, the sponsor for the convertible bond project, and Tianjian Accounting Firm also received penalties, with their representatives facing similar disciplinary actions [1] - This marks the first instance of a securities company receiving a regulatory letter from the Shenzhen Stock Exchange since the implementation of the registration system in the ChiNext board [1] Group 2: Investigation Findings - Citic Securities failed to adequately address multiple inquiries from the Shenzhen Stock Exchange regarding fund occupation and prepayment issues, leading to the issuance of a false commitment letter [2] - From 2018 to 2020, the major shareholder, Hangzhou Sichuan Medical Technology Group Co., Ltd., and its affiliates occupied a total of 338.457 million yuan in funds, with a maximum daily balance of 200.5015 million yuan [2] - Although the occupied funds were returned by April 30, 2021, the Shenzhen Stock Exchange had previously requested Citic Securities to verify the existence of non-operational fund occupation [2] Group 3: Due Diligence Failures - Citic Securities conducted a series of misleading operations, failing to properly investigate the purpose and accounting treatment of prepayments and investments, despite being aware of significant anomalies [3][4] - The firm issued a commitment letter that inaccurately stated there were no fund occupations by major shareholders, contradicting the actual situation [3] - The Shenzhen Stock Exchange criticized Citic Securities for not following due diligence standards and for providing inaccurate verification opinions [4] Group 4: Audit Firm Responsibilities - Tianjian Accounting Firm, responsible for the annual audits and the convertible bond project, also faced scrutiny for not adequately identifying and assessing the risks of fund occupation [6] - The firm failed to maintain reasonable professional skepticism and did not verify the flow of funds despite clear indications of potential issues [6] - The Shenzhen Stock Exchange noted that Tianjian's audit measures were insufficient, primarily relying on contract reviews and management interviews without proper verification of fund flows [6] Group 5: Regulatory Environment - The issue of fund occupation has been a recurring topic in the sponsorship work, with recent regulatory revisions aimed at enhancing the quality of due diligence in securities issuance [7] - The new regulations emphasize the need for sponsors to investigate the reasons and rationality behind receivables from related parties, particularly concerning potential fund occupations [7] - Regulatory bodies have been intensifying quality control measures for various investment banking projects, indicating a stricter oversight environment [7]