Hong Kong And The Mainland Continued To The Comparative Study Of The Information Disclosure System

During The last few years, there has been a substantial increase in the number of A&H dual listings in Hong Kong and the PRC. The increase brings challenge to both listing companies and regulators. As one of those important regulations, continuing disclosure regime is of great importance in security market and is crucial for the investors and the public to judge dual-listing companies. Dual-listing companies have to comply with continuing disclosure regime both in Hong Kong and in the mainland. While, there are differences between the two continuing disclosure regimes. If they continue to exist, the investors'interests will be badly damaged. Therefore, a comparison of the continuing disclosure regime both in Hong Kong and in the mainland is of great importance for the quality of continuing disclosure regime and for the investors'interests.Hong Kong is an international financial center, especially a global IPO hub. It attracts many listings of overseas issuers every year. Thus, the government has made it its strategic priority to maintain (if not further increase) its competitive edge in attracting listings of overseas issuers and in serving as an international financial center. This policy priority calls for continuous review of the regulatory framework, listing standards and disclosure requirements, to make capital market regulation in Hong Kong further comply with prevailing international practice. Meanwhile, gu gai in the mainland, currently near its completion, will essentially remove from the domestic capital markets a historically entrenched structural deficiency, therefore rationalizing the overall market structure and easing market conditions for new IPOs. This market condition is especially important to the launch of A-share IPOs of the returning H-share companies.We seek to address some of the most critical issues arising from the dual listing phenomenon: specifically, how to improve cross-border regulatory collaboration and how to achieve better rule compliance on continuing disclosure. The thesis is primarily concerned with helping further improvements in market transparency and regulatory quality through better synchronized enforcement of disclosure regimes on both Hong Kong and mainland exchanges to afford equal protection to investors in both markets. The creation of this thesis is that, from the perspective of dual-listing companies, it tries to introduce related items in the mainland to Hong Kong disclosure regime, finally make clear the differences between the two jurisdictions in Hong Kong and mainland.There are four chapters in this thesis, the first and second chapter, adopting a contrast method, analyses general differences between the two markets, such as the general frameworks and structures of the two disclosure regimes, procedures of disclosure required by two sets of laws and regulations, as well as common methods of disclosure. The third chapter discusses the main difference of the two jurisdictions. That is, four specific areas of continuing disclosure: disclosure of price-sensitive information, periodic financial reporting, disclosure of notifiable transactions and disclosure of connected transactions. The fourth and the last chapter is about how to promote the two jurisdictions. It is suggested that Hong Kong should improve transparency to disclose information and promote its competitiveness. At the same time, there should be strict regulatory sanction in the mainland. Also, the mainland and Hong Kong should have the same disclosure regime and cooperation in regulations.