Reply to the second round of examination and inquiry letter on the application documents for initial public offering and listing on the gem of Sichuan Zhongtai Joint Design Co., Ltd
Dxbz [2022] No. 800006
Daxin Certified Public Accountants (special general partnership)
WUYIGE CERTIFIED PUBLIC ACCOUNTANTS LLP.
Shenzhen Stock Exchange:
We have received the second round of examination and inquiry letter on the application documents of Sichuan Sino Thai joint design Co., Ltd. for initial public offering and listing on the gem (audit letter [2021] No. 011206) (hereinafter referred to as the “second round of examination and inquiry letter”) issued by your office on October 26, 2021. As the audit institution of Sichuan Sino Thai joint design Co., Ltd. (hereinafter referred to as “the company”), Daxin Certified Public Accountants (special general partnership) (hereinafter referred to as “we”), together with the company, Dongguan Securities Co., Ltd. and Beijing Deheng Law Firm, have carefully discussed and analyzed the issues listed in the inquiry letter based on the principles of diligence, honesty and trustworthiness, The relevant questions are replied as follows:
Question 1 About main business
The reply to the audit inquiry shows:
(1) The purpose of the real estate regulation policy is to promote the sustainable and stable development of the real estate industry, and then create a stable, reasonable and sustainable growth space for the market demand of architectural design business. The real estate regulation policy further improves the concentration of real estate enterprises and brings new growth opportunities to issuers.
(2) Relying on its comprehensive professional design ability, strong talent force and excellent service level, the issuer is in a leading position in the architectural design industry in Southwest China and has a high reputation in China State Construction Engineering Corporation Limited(601668) design industry.
(3) Evergrande real estate is the issuer’s second largest customer in 2020 and the fifth largest customer in 2018. At the same time, at the end of June 2020, the issuer receivable Evergrande commercial acceptance bill of 278661 million yuan.
Please the issuer:
(1) Supplement whether the discussion on the purpose and impact of macro policies in the real estate industry is accurate, cautious and logical; The specific impact of long-term regulation of the real estate industry on the issuer’s future project contracting, business operation, liquidity and fund recovery; Objectively and accurately prompt the risks related to industrial policies in the prospectus;
(2) Supplement the internal and external reasons and relevant basis for the growth and sustainability of the main business in combination with the industry development trend and core competitiveness;
(3) Supplement the sales revenue of Evergrande and rongchuang in each period of the reporting period, the amount and proportion of Evergrande and rongchuang in the orders in hand, and the amount of commercial acceptance bills and accounts receivable receivable from Evergrande and rongchuang by the issuer in each period; Specific adverse changes in business operation, main financial indicators and liquidity of rongchuang, Evergrande and other real estate customers and other regional small and medium-sized real estate customers, and whether the above adverse changes have a significant adverse impact on the issuer’s business and sustainable operation ability; Fully prompt the business risks caused by changes in the liquidity status of major customers;
(4) Supplement the comparison with comparable companies in Southwest China in terms of operation, market position, technical strength, qualification, technicians with business qualification, key business data and indicators to measure core competitiveness, quantitatively analyze the advantages and disadvantages of relevant competition, and objectively explain the market positioning and industry position in Southwest China;
(5) Combined with macro policy, main business, business model, technical level, R & D intensity, growth and other factors, analyze and explain whether it has the characteristics of “three innovations and four innovations” and whether it is in line with the positioning of gem.
The sponsor, the issuer’s lawyer and the reporting accountant are requested to express clear opinions on the above issues, and explain whether there are significant adverse changes in the issuer’s sustainable operation ability in combination with the impact of relevant policies of the real estate industry on major downstream customers. [company reply]
1、 Supplement whether the discussion on the purpose and impact of macro policies in the real estate industry is accurate, cautious and logical; The specific impact of long-term regulation of the real estate industry on the issuer’s future project contracting, business operation, liquidity and fund recovery; In the prospectus, the risks related to industrial policies are objectively and accurately prompted.
(I) whether the discussion on the purpose and impact of macro policies in the real estate industry is accurate, cautious and logical
1. On the purpose and influence of macro policies in the real estate industry
(1) Main contents of the central economic work conference on the real estate industry in recent years
Time: main contents about the real estate industry
In December 2016, we promoted the steady and healthy development of the real estate market. We must insist that the house is used for housing, not for the purpose of frying, and we should change radically the basic system and long-term mechanism that conforms to the national conditions and adapt to the market rules by comprehensively using 14-16 days’ finance, land, taxation, investment, legislation and other means to curb the real estate bubble and prevent the ups and downs.
In December 2017, accelerate the establishment of a housing system with multi-body supply, multi-channel guarantee and simultaneous rent and purchase. The meeting proposed to develop the 18-20 day market of Housing leasing City, especially long-term leasing, and improve the long-term mechanism to promote the stable and healthy development of the real estate market.
In December 2018, we should establish a long-term mechanism for the healthy development of the real estate market, adhere to the positioning that houses are used for living and not for speculation, implement policies and classified guidance from 19 to 21, consolidate the main responsibility of the urban government, and improve the housing market system and housing security system.
We should increase the housing security work for the urban poor, strengthen the urban renewal and upgrading of existing housing, do a good job in the transformation of old urban communities in December 2019, and vigorously develop rental housing. We should adhere to the positioning that houses are used for living rather than speculation, fully implement the long-term management and regulation mechanism of implementing policies for cities from October to December, and stabilize land prices, house prices and expectations, so as to promote the steady and healthy development of the real estate market.
Solve the prominent housing problems in big cities in August. We should adhere to the positioning that the house is used for living, not for speculation, and take measures according to local conditions to promote the steady and healthy development of the real estate market. We should attach great importance to the construction of indemnificatory rental housing, accelerate the improvement of the 16-18 day long rental housing policy, gradually make rental and purchase housing have the same right to enjoy public services, and standardize the development of the long rental housing market.
In August, we should adhere to the positioning that houses are used for living rather than speculation, strengthen the expected guidance, explore new development models, adhere to the simultaneous development of rent and purchase in December 2021, accelerate the development of long-term rental housing market, promote the construction of indemnificatory housing, and support the commercial housing market to better meet the reasonable housing needs of buyers from August to October, Implement policies to promote the virtuous circle and healthy development of the real estate industry.
(2) Main contents of the government work report on the real estate industry in recent years
Time: main contents about the real estate industry
Adhere to the residential attribute of housing, implement the main responsibility of local governments, accelerate the establishment and improvement of a long-term mechanism to promote the stable and healthy development of the real estate market, improve the housing system of both purchase and rent, focus on the market to meet multi-level needs, and provide basic security for 2017 with the government. Strengthen the classified regulation and control of the real estate market. Cities under great pressure of rising house prices should reasonably increase residential land, standardize the development, sales, intermediary and other behaviors, and curb the rapid rise of house prices in hot cities.
Adhere to the positioning that houses are used for living rather than speculation, implement the main responsibilities of local governments, continue to implement differentiated regulation, establish and improve the long-term mechanism in, and promote the steady and healthy development of the real estate market. We will support residents’ demand for home ownership, foster the housing rental market and develop housing with common property rights. We will accelerate the establishment of a housing system with multi-body supply, multi-channel guarantee and simultaneous rent and purchase, so that the broad masses of the people can live in peace and contentment as soon as possible.
In, we will better solve people’s housing problems, implement the main responsibilities of cities, reform and improve the housing market system and security system, and promote the steady and healthy development of the real estate market in 2019.
In 2020, adhere to the positioning that houses are used for living, not for speculation, and implement policies due to the city to promote the steady and healthy development of the real estate market.
Adhere to the positioning that the house is for living, not for speculation, and stabilize the land price, house price and expectation. Solve the prominent problem of new year housing in big cities, effectively increase the supply of affordable 2021 rental housing and housing with common property rights through increasing land supply, arranging special funds and centralized construction, standardize the development of long-term rental housing market, reduce the tax burden of rental housing, and try our best to help new citizens and young people alleviate their housing difficulties.
(3) Other relevant policies or meeting requirements on the real estate industry
Time Name: main contents about the real estate industry
The Ministry of housing and urban rural development and the central bank held a symposium on key real estate enterprises in August 2020 to further implement the long-term mechanism of real estate, implement the prudent management system of real estate finance, and enhance the marketization, regularization and transparency of real estate enterprise financing; Form rules for fund monitoring and financing management of key real estate enterprises (“three red lines” financing new rules).
In December 2020, the notice on the establishment of banking finance, setting the concentration of real estate loans of real estate institutions according to the asset scale, institution type and other factors, and encouraging real estate enterprises to change from high turnover and high leverage mode to long-term management system.
In 2021, the Ministry of natural resources will organize a meeting, and all localities will take effective measures to guide the rational competition in the residential land market. Key cities should reasonably arrange the timing of bidding, auction and hanging out for residential land in February, that is, release the transfer announcement and organize the transfer activities, In principle, the centralized transfer of residential land in key cities throughout the year shall not exceed three times.
Implement a long-term mechanism for the steady and healthy development of the real estate market, Promoting real estate and real economy Balanced national development of the people’s Republic of China. We will adhere to the position that houses are used for living, not for speculation. We will accelerate the establishment of a housing system with multi-agent supply, multi-channel security and simultaneous rental and purchase in 2021, so that all people can live in a far better balance between the three-month five-year plan and 2035. We will adapt measures to local conditions and adopt multiple policies , consolidate the overall responsibility of the outline of the main objectives of the urban government, and stabilize land prices, house prices and expectations. We will establish a linkage mechanism between housing and land, strengthen financial regulation of real estate, give full play to the regulatory role of housing tax, support reasonable home ownership demand and curb speculative investment demand.
In 2021, the monetary policy of the people’s Bank of China will safeguard the healthy development of the real estate market and the legitimate rights and interests of housing consumers.
September Committee third quarter 2021
Time Name: main contents about the real estate industry
Regular meeting
The meeting stressed that the financial sector should conscientiously implement the decisions and arrangements of the Party Central Committee and the State Council, accurately grasp and implement the financial and prudent management system of real estate gold jointly convened by the central bank and the CBRC in 2021, and adhere to the positioning that houses are used for living, not for speculation, In September, the Symposium on real estate finance held that real estate should not be used as a short-term means to stimulate the economy, continued to implement the long-term mechanism of real estate, and accelerated the improvement of the housing rental financial policy system. The meeting required that financial institutions should, in accordance with the principles of legalization and marketization, cooperate with relevant departments and local governments to jointly maintain the steady and healthy development of the real estate market and safeguard the legitimate rights and interests of housing consumers.
Some financial institutions have some misunderstandings about the “three lines and four grades” financing management regulations of 30 pilot real estate enterprises, and the financial system in October 2021 and the third quarter of 2021, resulting in the tight capital chain of some enterprises to a certain extent. The central bank and the China Banking and Insurance Regulatory Commission held a symposium on real estate finance at the end of September to guide major banks
