QFII Disclosure Key Points
The information disclosure requirements for Qualified Foreign Institutional Investors (Referred to as "QFII") include four aspects.
Main body of the information disclosure. QFII as well as ultimate investors shall be the main body of information disclosure.
Channels of information disclosure. There are two channels, including disclosing by Secretary of the Board of Directors of the listed company who is notified by QFII, and by Secretary of the Board of Directors of the listed company who is noticed by ultimate investors via QFII.
Time requirement. If shareholdings of a listed company reach up to 5% for the first time, then the holder shall disclose the Report of Changes in Equity within 3 days, and stop further share trading. If shareholdings of a listed company change 5% in subsequent increase or decrease, according to the above mentioned provisions of reporting and announcement, the holder shall complete the report and make an announcement. No further shares trading of the listed company is allowed within 2 days after the announcement has been made. In practice, the main body of the information disclosure can firstly disclose an announcement and then release the report. For more detail, please see in the Acquisition Management Approach of the Listed Company (Commission Order No. 35 [2006]).


Calculation of shareholding. 1. When a QFII or an ultimate investor fulfills the disclosure obligations, he should combine domestic shares and overseas shares of the same listed company for calculation. 2. Multiple accounts of the same QFII of a listed company should be combined for calculation. 3. For actual investors who hold a listed company's shares through multiple QFII accounts, the amount of shares is the total amount of different QFII accounts. For more detail, please see in Measures on the Administration of the Takeover of Listed Companies (CSRC Decree [2006] No. 35), Qualified Foreign Institutional Investors Invest in Domestic Securities Management Measures (Decree 36 of 2006), Issues on the Implementation of the Rules Governing the Qualified Foreign Institutional Investors Invest in Domestic Securities (CSRC Announcement [2012] 17), Implementation Rules Governing the Qualified Foreign Institutional Investors Invest in Domestic Securities in Shanghai Stock Exchange (2002, 2012 proposes to amend).