After all the finishing work in Board of Directors at the end of the year, the pace in Henglong Headquarters Building has not slowed down.
On the afternoon of the day when Chen Wei's real estate closing report was filed, Zhang Qingxue knocked on the door of Zhao Chen's office.
She held a document that was not too thick in her hand,
The words "Henglong Capital A-share Position Compliance Adjustment Contingency Plan (Draft)" are printed on the cover, and a red seal of "Internal Discussion Only" is marked in the lower right corner.
She just came back from Shanghai attending a symposium jointly convened by Securities Regulatory Commission Legal Department and Institutional Department--
This kind of closed-door meeting is not open to the public, and there are no official minutes.
However, it was mentioned at the meeting that Securities Regulatory Commission is drafting a new management method for shareholders of Listed Company to reduce their holdings.
It is proposed to impose stricter restrictions on shareholding reductions for shareholders holding more than a certain proportion of shares.
Zhang Qingxue took ten pages of notes at the meeting, and on the plane back to Shan City compiled the key points into this Contingency Plan.
"Zhao Zong, next year Henglong may have to face a more complicated round of regulatory adjustments on A-share's position than Hong Kong Stock Exchange."
She sat down on the sofa and put the documents on the coffee table.
Su Wantang The Zisha Pot left in the cabinet has just been refilled with hot water by the new assistant.
The fragrance of tea still filled the air quietly, but Zhang Qingxue did not hold the tea cup.
She sat upright as usual, with her glasses pushed up on the bridge of her nose.
There was a calmness typical of legal personnel in his tone, but there was also a rare sense of urgency.
"What exactly does this symposium involve?"
"There are only two core points."
Zhang Qingxue opened the first page of the document and clicked on the summary of terms one by one with his finger.
"First, Major Shareholder, which holds more than 5% of the shares, reduces its holdings through Secondary Market.
It may be necessary to announce the reduction plan in advance to give the market time to react.
This is currently only a discussion at the window guidance level.
But once the direction of discussion is formed, it will enter the formal drafting process of regulations.
The second article is more critical - shareholders who hold more than a certain proportion of shares,
The cumulative reduction ratio in each consecutive period may be subject to stricter restrictions.
It is no longer as loose as it is now, where the reduction can be 1% to 2% every quarter."
She raised her head and looked at Zhao Chen.
Henglong Capital's five positions in A-share--
Bidiya 4.99%, Pianzaihuang 2.65%, Tongce Medical 4.99%, Shanxi Fenjiu 4.99%, Wuliangye 0.62%--
The current total market value of RMB is approximately 22 billion yuan, accounting for the most liquid part of Henglong's net assets.
Among them, Bidiya is the one with the heaviest position, with a total position of about 136 million shares and a current market value of about 11.5 billion.
The time of opening these five stocks spans from 2017 to 2018.
Every purchase was accurately made at the bottom of the industry cycle. Zhao Chen has never sold a single share in any round of market fluctuations.
But the question now is not whether to sell it, but if the regulatory rules change,
Henglong Can you still manage these positions at your own pace?
"Fenjiu and Tongce currently stop at 4.99%, only one step away from the 5% threshold.
We originally controlled this position deliberately so as not to trigger the obligation to raise a sign.
But if the new regulations further lower the threshold for reduction restrictions from 5%,
Or a broader definition of 'holding more than a certain proportion of shares',
Then the future compliance space of our stocks will be significantly squeezed.
Once the shareholding reduction plan announcement system is implemented, any shareholding reduction that exceeds the threshold needs to be announced in advance.
The market will react in advance and our operating window will be greatly narrowed.
The worst case scenario is that you could have waited until the stock price rose to a price you thought was appropriate before reducing your holdings.
But once the new regulations take effect, you may need to make an announcement far enough in advance.
Fluctuations in stock prices during the announcement period will in turn affect the reduction strategy itself."
Zhao Chen Turn to the third page of the document,
Listed there are the position opening time, cost, current floating profit, and
And the complete exit cycle roughly estimated based on the maximum reduction speed allowed by existing rules.
The fastest one is Wuliangye--with a shareholding of only 0.62%, it is difficult to be stuck even under the strictest new regulations.
The slowest one is Bidiya - according to the existing rules, Secondary Market can reduce holdings by up to 1% each quarter.
At this rate it would take more than a year to drop from the current 4.99% to zero.
If the new regulations are further tightened, this time will be extended even longer.
But Zhang Qingxue marked a line of small words with a red pen in the remarks next to the column of Bidiya:
"This is a long-term ballast asset and will not be reduced in principle. The reduction cycle is theoretically calculated for reference."
She is not suggesting to reduce holdings of Bidiya,
Instead, objectively list all targets that may be affected.
Regardless of whether Zhao Chen has any intention to reduce its holdings in them.
"Then what is your suggestion?" Zhao Chen asked.
"Make compliance adjustments in advance instead of reacting passively until the new regulations are implemented."
Zhang Qingxue turned to the fourth page of the document, which showed a detailed timetable and operation path map.
The recommended adjustment methods and response priorities for each position are clearly marked.
"No matter how the final version of the new regulations is decided, there are a few things we can do in advance.
First, diversify shareholdings.
For targets with a shareholding ratio close to 5%,
You can consider transferring some positions to different SPV accounts under Henglong Capital through block transactions or agreement transfers at an appropriate price and time window.
But it is not a real reduction of holdings - it is just an adjustment of the main holdings, and the total position remains unchanged.
The advantage of this is that when calculating the shareholding ratio of a 'single shareholder',
The positions held by different SPVs are legally regarded as different shareholding entities.
This leaves room for future flexibility without changing our judgment and holding intention for the company Fundamentals.
Second, optimize the priority of holding reduction.
If the new regulations are indeed tightened more than expected,
We need to know which targets have the highest priority for reduction and which ones can continue to be held.
Wuliangye has a low proportion and good liquidity, and has the highest priority for reduction;
Bidiya and Green Energy Technology are long-term Core Assets, with the lowest priority.
Third, lock in counterparties for large transactions and agreement transfers in advance.
The new regulations generally have looser restrictions on large transactions and agreement transfers than Secondary Market direct reduction of holdings.
If Henglong really needs to reduce its holdings in compliance with regulations in the future, it is safer to go for block or agreement transfer than to place an order directly on Secondary Market."
Zhao Chen flipped through the document from beginning to end.
Zhang Qingxue's Contingency Plan is well written, not only analyzing the most stringent possible version of the new regulations,
It also leaves room for Henglong to flexibly adjust after the new regulations are implemented.
Every risk point was marked by her in advance.
He remembered what Shen Jue said at the year-end Board of Directors--
"Once a system is established, it will not collapse due to changes in any one person."
What Zhang Qingxue is doing now is to help Henglong build a regulatory "system" in advance.
"I approve this Contingency Plan.
Legal Department will take the lead, and the Investment Department will cooperate, and strive to come up with a specific operation plan as soon as possible within three months."
Zhang Qingxue nodded, put away the files and prepared to leave.
When she reached the door, she paused and did not look back.
"Zhao Zong, there is something I have always wanted to say.
Last time at United States, you had to pledge your Henglong shares in order to supplement your margin.
That will never happen again - not because you have enough personal assets,
It's because Henglong now has a real institutional firewall.
The response to today's new regulations on reduction of holdings Contingency Plan is the same as the previous bank credit that has not been used yet.
They are all part of this firewall."
After saying that, she opened the door and the footsteps in the corridor gradually became distant.
Zhao Chen leaned back in his chair and opened the document on the coffee table marked "Internal Discussion Only" to the last page.
That was a handwritten note by Zhang Qingxue, with only one sentence -
"This Contingency Plan was completed in December 2019, and formal adjustments are expected to start in the next 6 to 12 months."
He picked up the pen and wrote a line below this sentence:
"Aunt Zhang's judgment has always been ahead of supervision. Don't rush, but don't stop."
Then close the file and put it on the table.
Henglong Every hurdle experienced this year--
The closure of Stock Exchange, the collapse of Short Sellers, and the return of the stock price from 40 to 100 - are all in the past.
Zhang Qingxue The document placed on his desk is the future that is knocking on the door.