Lately, the National Association of Financial Market Institutional Investors has revised and issued the Administrative Measures on Registration Experts in Debt Financing Instruments of Non-Financial Enterprises (the "Measures") which will enter into force as of the date of promulgation.
The Measures make it clear that registration experts shall be made up of representatives from investors, underwriters, accounting firms, law firms, rating agencies and other institutions, among which investors' representatives shall account for at least 30 percent. According to the Measures, registration experts shall be responsible for reviewing and discussing the completeness of information to be disclosed in registration files, urging issuers and intermediate service agencies to improve information disclosure, and offering professional advisory opinions on registration etc. Registration experts will not make any substantial judgement over the investment value and investment risks relating to any debt financing instrument of a non-financial enterprise. Furthermore, the Measures provide that a registration expert shall propose to recuse himself or herself in case of any of four circumstances, such as "where such expert or the unit in which he or she works acts as the managing underwriter or provides rating, auditing, legal or other relevant services for the project to be reviewed and discussed".