The SEC's closing letter was delivered on Wednesday morning.
No email, no fax.
An official letter bearing the SEC blue badge is contained in Kraft Paper Envelope,
The FedEx courier personally delivered it to the front desk of Era Vanguard New York Office.
Lin Shicheng was reviewing the Schedule 13D Amendment Filing draft of Nvidia when he received the call from the front desk.
He put down his pen and said, "I'll be down right away." Then he tied his tie, walked down the stairs to the first floor, and signed for the envelope himself.
The envelope is very thin, so thin that one wonders if there is only a piece of paper inside.
Lin Shicheng did not open it at the front desk, but took the envelope and walked back to the elevator, feeling its weight in the rising silence.
He mentally went through every round of games with the SEC in the past six months--
Two inquiry letters, four dossier attachments, countless late-night cross-checks,
And the final reply letter that he himself called "a model of industry compliance."
The thin envelope in my hand at this moment is the end of it all.
He walked into Meeting Room, put the envelope on the table, opened the seal with a letter opener, and took out the letter inside.
The letter only has two pages. The first page is the SEC's official closing notice, which is concise and clear--
"After review, the description of the source of funds submitted by Times Pioneer Capital is complete, accurate, and consistent with the attached transaction records.
This committee determines that the initial source of funds of Era Vanguard is legal and compliant and will not initiate formal investigation procedures."
The second page is Supplementary Explanation, and there is a paragraph that Lin Shicheng read three times--
"This committee also determined that the reports submitted by Muddy Waters research and Citron Capital between May and June 2019 regarding the source of funds of Era Vanguard lacked substantive evidence and will not be accepted."
He put the letter on the table, took off his glasses, wiped the lenses, and took a long breath.
Then he picked up the intercom phone on the table and dialed the number Zhao Chen.
The phone rang once and was connected. Lin Shicheng's voice was smooth and normal.
There is no difference from the usual reporting work, but every word is like a spring that has been pressed for half a year and finally loosened.
With a very subtle relaxation that only those who have worked with him the longest can detect.
"Zhao Zong, the SEC's closing letter has arrived.
It is formally confirmed in writing that no investigation will be initiated and that all sources of funds are legal and compliant.
The reports of Muddy Waters and Citron were dismissed."
There was silence on the other end of the phone for a moment. Then Zhao Chen's voice came over, as steady as usual.
But Lin Shicheng heard him pause after saying "I know",
It was as if he was weighing the weight of those three words on the tip of his tongue.
Then he added - "Thank you for your hard work, Lawyer Lin."
Lin Shicheng hung up the phone and wrote a few lines in his notebook.
He needs to do several things immediately:
Notify Zhang Qingxue and Chen Xi to let Henglong Legal Department and the capital team update the regulatory compliance files simultaneously;
Prepare a brief media briefing, the wording should be restrained enough and not give the SEC the impression that "Era Vanguard is getting carried away";
And filing--the SEC's two inquiry letters, Era Vanguard's four-document response letter, and this closing letter,
All are bound into a volume and stored in the permanent compliance file of Era Vanguard.
He wrote in his notebook:
"Notification Principles:
1. Confirm the case is closed and do not initiate an investigation;
2. Confirm that the source of funds is legal and compliant;
3. Confirm that the reports of Muddy Waters and Citron have been rejected;
4. Do not make any additional comments."
After writing these four lines, he leaned back in his chair, his eyes fell on the water Hudson River outside the window, and the corner of his mouth curled up with a very faint arc.
In the past six months, every document he has handled, every transaction record he has checked, and every line of legal opinion he has written,
In the end, they were all put into the four files in EDGAR System and replaced with a two-page closing notice from the SEC.
Is it worth it? He asked this question in his mind, and then answered himself - of course it is worth it.
In the afternoon of the same day, he made a brief briefing to several major Financial Media through the cooperation channels of the law firm.
The wording follows the established principles without any additional modifications.
Bloomberg was the first to send out the news, with a concise title--
"Era Vanguard Statement: SEC has confirmed that the source of funds is legal and will not initiate investigation procedures."
Reuters's follow-up report added more details, including the fact that the case closing letter clearly mentioned that the reports of Muddy Waters and Citron lacked substantive evidence and would not be accepted.
CNBC spent three minutes on its lunchtime program interpreting the report piece by piece. The host finally concluded:
"This is a complete victory for Era Vanguard. The SEC's closing letter not only confirmed that the source of funds was compliant, but also directly rejected the report of Short Selling.
This level of regulatory endorsement is very rare for an offshore fund."
When the news reached China, Zhang Qingxue was in the Henglong Legal Department's office overnight reviewing Yunnan Agriculture Group IPO's due diligence report.
Her phone vibrated on the table. It was a message from Lin Shicheng, with only one line -
"Case closed. Formal correspondence filed. Notice sent."
She read this sentence twice, and then forwarded it to Chen Xi and Su Wantang. When forwarding, she added a sentence of her own:
"This case closing letter should be framed and hung on the wall of the Henglong Legal Department."
Chen Xi's reply arrived almost in seconds--
"Don't frame it, make a photocopy. Send a copy to each Independent Director."
Su Wantang's reply came after a while, with only three words--
"Got it."
But Zhang Qingxue noticed that her input status lasted for a long time--
I kept typing, deleting, typing again, deleting again, and finally only these three words came out.
Zhang Qingxue thought for a moment and did not ask further questions. She knew what Su Wantang was probably thinking at the moment.
Unlike them, Su Wantang watched Zhao Chen go from scratch to today with his own eyes.
The closing letter was a compliance victory for them and a legal conclusion, but for her,
It was the moment of trance when all the evidence chains were tightly connected and finally sealed and sealed.
At the same time, in Manhattan's hotel Suite,
Zhao Chen forwarded the scanned copy of the case closure letter sent by Lin Shicheng to Elon Musk, with a line attached:
"SEC's final conclusion. Era Vanguard's money is clean."
Elon Musk's reply arrived quickly, in his usual style--
"I know." Followed by another one:
"You are the most disciplined offshore fund owner I have ever seen. Keep it up."
Zhao Chen did not reply immediately, but looked at the two lines of words on the phone, with a very faint arc at the corner of his mouth.
He put his cell phone on the coffee table, picked up the tea cup and took a sip.
Then he leaned on the sofa and looked across Floor-to-Ceiling Window, landing on the Hudson River's water surface illuminated by the sparkling July sun.
His mood was calmer than the river outside the window.
Starting from November 2018 when Era Vanguard submitted its first 13D declaration,
For more than a year, he has always known that this day would come -
It's not a question of whether the SEC can be persuaded, it's a question of whether the SEC has the courage to be convinced.
Because what he handed them was not a statement of defense, but an answer sheet signed by himself a few years ago.
And now, the grader finally wrote the number he expected in the scoring column.
Outside the window, the water Hudson River is still flowing silently to the sea, exactly the same as yesterday.