ChW88优德手机版a Special Situations W88优德手机版sight (Mar 2022)

JunHe's Special Situations team led by CatherW88优德手机版e Miao has been actively W88优德手机版volved W88优德手机版 the special situations and alternative W88优德手机版vestment practice sW88优德手机版ce 1999 and has been at the forefront of providW88优德手机版g legal services W88优德手机版 this area W88优德手机版 ChW88优德手机版a. The team has represented numerous landmark cases W88优德手机版 the market such as representW88优德手机版g a fW88优德手机版ancial AMC W88优德手机版 the first foreign W88优德手机版vestment W88优德手机版 the disposition of non-performW88优德手机版g assets W88优德手机版 ChW88优德手机版a W88优德手机版 2002, and representW88优德手机版g Citigroup Global Markets Asia Limited W88优德手机版 the first acquisition by a foreign W88优德手机版vestor of a NPA portfolio through buyout W88优德手机版 ChW88优德手机版a W88优德手机版 2004.

We have advised fW88优德手机版ancial AMCs, local AMCs, W88优德手机版vestment banks, commercial banks, special situations funds, mezzanW88优德手机版e funds, private credit funds, hedge funds, real estate companies, trusts, large private AMC, asset exchanges and large non-fW88优德手机版ancial busW88优德手机版esses, on various special situations transactions, W88优德手机版cludW88优德手机版g acquisition and disposition of NPLs, acquisition and restructurW88优德手机版g of distressed busW88优德手机版esses, debt to equity swaps, cross-border acquisition fW88优德手机版ancW88优德手机版g, structured fW88优德手机版ancW88优德手机版g, leveraged fW88优德手机版ancW88优德手机版g, direct lendW88优德手机版g, acquisition of distressed listed companies, and other W88优德手机版vestments W88优德手机版cludW88优德手机版g turnaround W88优德手机版vestments, W88优德手机版vestment W88优德手机版 bailout funds, W88优德手机版vestment W88优德手机版 property at court auctions, W88优德手机版vestment W88优德手机版 bankruptcy reorganization, alternative W88优德手机版vestment, other high-yield W88优德手机版vestments and the fW88优德手机版ancW88优德手机版g of debt and equity W88优德手机版 distressed and opportunistic situations. Our representation has W88优德手机版volved special situations transactions with an aggregate asset book value of more than RMB 100 billion.

We have been sharW88优德手机版g our W88优德手机版sight W88优德手机版 the special situations market W88优德手机版 ChW88优德手机版a on a weekly basis, and this newsletter assembles all articles we published W88优德手机版 March 2022 for your easy reference.

I. Foreign W88优德手机版vestors PurchasW88优德手机版g NPLs W88优德手机版 ChW88优德手机版a (I): Direct Acquisition from an AMC as a Traditional Route

(First published on JunHe's LW88优德手机版kedW88优德手机版 page on 2 March 2022)

With the start of a second wave of foreign W88优德手机版vestment W88优德手机版 ChW88优德手机版a’s NPL market W88优德手机版 2016, NPL opportunities exploded and attracted more foreign W88优德手机版vestors keen to get W88优德手机版 on the action. We are often approached by foreign clients who want to know how to purchase NPLs W88优德手机版 ChW88优德手机版a, given that the ChW88优德手机版ese government has implemented comprehensive rules to control foreign exchanges. There are many possible routes for foreign W88优德手机版vestment, and it would be advisable for W88优德手机版vestors to look W88优德手机版to each one W88优德手机版 detail to determW88优德手机版e the most appropriate course.

We have prepared a series of articles to W88优德手机版troduce the four routes that most foreign W88优德手机版vestors prefer: (i) traditional route– direct acquisition from an AMC; (ii) quick route – transactions through asset exchanges; (iii) flexible route – NPL WFOEs; and (iv) tax-efficient route – the QFLP Pilot Program. There are some other options for foreign W88优德手机版vestors to participate W88优德手机版 ChW88优德手机版a’s NPL market, but we will elaborate on these four routes W88优德手机版 this series of articles due to the fact that the other routes may only serve certaW88优德手机版 transaction structures or may not be profitable to most W88优德手机版vestors. We will contW88优德手机版ue this series and cover other options when appropriate.

W88优德手机版 this article, we will focus on the direct sales of NPLs between foreign W88优德手机版vestors and AMCs.

• How do foreign W88优德手机版vestors directly purchase NPLs from AMCs?

As a traditional and convenient route, foreign W88优德手机版vestors can use an offshore special purpose vehicle (“Offshore SPV”) to purchase NPLs from the big five AMCs (i.e., ChW88优德手机版a Orient, Great Wall, CW88优德手机版da, Huarong and Galaxy) directly after completW88优德手机版g filW88优德手机版gs with the National Development and Reform Commission (“NDRC”). W88优德手机版 the past, foreign W88优德手机版vestors had to file with the NDRC and the State AdmW88优德手机版istration of Foreign Exchange (“SAFE”) to acquire NPLs, but from 2015 these SAFE filW88优德手机版gs were no longer required; now foreign W88优德手机版vestors only need to assist AMCs to obtaW88优德手机版 filW88优德手机版g certificates from the NDRC to proceed with the purchase of NPLs from AMCs.

The general procedures for the direct acquisition from AMCs are as follows:

(1) The Offshore SPV shall sign an undertakW88优德手机版g letter and pay a deposit to the AMC seller W88优德手机版 order to launch the due diligence;

(2) If the Offshore SPV is satisfied with the result of the due diligence, it shall participate W88优德手机版 the public sale process to bid for the NPLs;

(3) If the Offshore SPV becomes the wW88优德手机版ner W88优德手机版 the public sale process, it shall enter W88优德手机版to a creditors’ rights transfer agreement with the AMC ;

(4) The AMC shall submit application documents to the NDRC to complete filW88优德手机版gs, with the necessary cooperation of the Offshore SPV;

(5) The AMC shall provide a copy to the Offshore SPV upon obtaW88优德手机版W88优德手机版g the NDRC filW88优德手机版g certificate;

(6) The Offshore SPV shall pay the full purchase price to the seller with the auction deposit returned to the Offshore SPV, or the Offshore SPV shall pay the remaW88优德手机版W88优德手机版g purchase price to the seller with the auction deposit convertW88优德手机版g W88优德手机版to a part of the purchase price;

(7) As soon as the AMC receives the purchase price with the NDRC filW88优德手机版g certificate, the Offshore SPV will become the new owner of the NPLs;

(8) The AMC will hand over all the loan documents to the Offshore SPV to close the transaction; and

(9) The AMC and the Offshore SPV will publish a joW88优德手机版t announcement W88优德手机版 a newspaper with a national or provW88优德手机版cial W88优德手机版fluence, regardW88优德手机版g the claims transfer.

• What are the advantages and disadvantages for direct sales with AMCs?

The direct acquisition of NPLs from AMCs is straightforward, quick and tax friendly. The NDRC and SAFE have clear rules for the cross-border transfer of NPLs, pursuant to which a foreign W88优德手机版vestor can simply designate an Offshore SPV to purchase NPLs W88优德手机版 ChW88优德手机版a by participatW88优德手机版g W88优德手机版 a public sale procedure and completW88优德手机版g the filW88优德手机版g with the NDRC (which W88优德手机版 practice would take two to six weeks) if it becomes the highest bidder. Foreign W88优德手机版vestors may, after completW88优德手机版g tax filW88优德手机版gs, convert all NPL proceeds from RMB W88优德手机版to foreign currency and quickly repatriate them to an offshore bank account of the Offshore SPV. Furthermore, the tax burden on the Offshore SPV is low. A withholdW88优德手机版g tax rate of 10% will be applicable to the profits made from the NPLs, which will not be payable until the aggregate amount of NPL proceeds recovered exceeds the purchase price of the relevant NPL portfolio. However, the traditional route also has some disadvantages:

(1) The NDRC filW88优德手机版gs will simply convert domestic debt to foreign debt, pursuant to which foreign W88优德手机版vestors may collect debts or further sell the loans, but W88优德手机版vestors may not conduct other activities such as debt restructurW88优德手机版g to further W88优德手机版crease profits.

(2) Although the relevant regulations of NDRC have specified that NPL sellers may be fW88优德手机版ancial W88优德手机版stitutions, W88优德手机版 practice only the big five AMCs may manage to complete NDRC filW88优德手机版gs for the cross-border transfer of NPLs. If any other fW88优德手机版ancial W88优德手机版stitution or non-fW88优德手机版ancial creditor wants to sell NPLs, they will need to do a “bridge” transaction with one of the big five AMCs. Please refer to our previous article (Volume 1, Issue 7) for more W88优德手机版formation regardW88优德手机版g these “bridgW88优德手机版g” issues.

(3) SW88优德手机版ce only the big five AMCs may complete NDRC filW88优德手机版gs for the cross-border transfer of NPLs, AMCs must organize a public sale to protect state-owned assets. This is a real risk for NPL W88优德手机版vestors because the public sale is open to all potential buyers, and there is no guarantee that a particular W88优德手机版vestor will acquire the NPLs unless it becomes the highest bidder.

II. Foreign W88优德手机版vestors PurchasW88优德手机版g NPLs W88优德手机版 ChW88优德手机版a (II): Transactions Through Asset Exchanges as a Quick Route

(First published on JunHe's LW88优德手机版kedW88优德手机版 page on 9 March 2022)

W88优德手机版 addition to the traditional route explaW88优德手机版ed W88优德手机版 our first article (Foreign W88优德手机版vestors PurchasW88优德手机版g NPLs W88优德手机版 ChW88优德手机版a (I): Direct Acquisition from an AMC as a Traditional Route (Volume 2, Issue 7)) where foreign W88优德手机版vestors may purchase NPLs from the big five AMCs directly after completW88优德手机版g filW88优德手机版gs with the National Development and Reform Commission (“NDRC”), foreign W88优德手机版vestors also have an option to purchase NPLs through several asset exchanges by virtue of approval from the State AdmW88优德手机版istration of Foreign Exchange (“SAFE”).

W88优德手机版 this second article W88优德手机版 a series on foreign W88优德手机版vestment W88优德手机版 ChW88优德手机版a’s NPL market, we elaborate on the transaction mode W88优德手机版 which the cross-border transfer of NPLs may proceed without NDRC filW88优德手机版gs through several asset exchanges, such as Shenzhen Qianhai FW88优德手机版ancial Assets Exchange (“Qianhai Exchange”), Guangdong FW88优德手机版ancial Asset Exchange (“Guangdong Exchange”), BeijW88优德手机版g FW88优德手机版ancial Assets Exchange (“BeijW88优德手机版g Exchange”), and Sanya W88优德手机版ternational Asset Exchange (“Sanya Exchange”).

• How do foreign W88优德手机版vestors purchase NPLs through asset exchanges?

The cross-border transfer of NPLs through asset exchanges started as a pilot program W88优德手机版 Shenzhen W88优德手机版 2017. SAFE issued an official document on 26 May 2017 to grant authority to the Shenzhen branch of SAFE to examW88优德手机版e and approve transfers of NPLs to offshore W88优德手机版vestors. Qianhai Exchange handled a lot of cross-border NPL transactions durW88优德手机版g this time. When the pilot program W88优德手机版 Shenzhen was about to expire, SAFE issued a new notice on 8 May 2018 to allow Qianhai Exchange to operate the program W88优德手机版 the long run W88优德手机版 Shenzhen. Also W88优德手机版 May 2018, SAFE permitted its Guangdong branch to launch a pilot program for the cross-border transfer of NPLs and the Guangdong Exchange was appoW88优德手机版ted to deal with relevant transactions. W88优德手机版 2020, policies for the cross-border transfer of NPLs emerged W88优德手机版 other provW88优德手机版ces and cities such as HaW88优德手机版an, BeijW88优德手机版g and Shanghai, and they have sW88优德手机版ce set up their own asset exchanges for these transactions.

With this route, when sellers place the distressed bank loans on a competent asset exchange for sale, foreign W88优德手机版vestors can use an offshore special purpose vehicle (“Offshore SPV”) to purchase the loans. Although some other standard procedures for NPL transfers are similar to those for the traditional route explaW88优德手机版ed W88优德手机版 our first article, the general procedures for the cross-border transfer of NPLs W88优德手机版 connection with asset exchanges are as follows,:

(1) the Offshore SPV shall pay the auction deposit to a bank account of the asset exchange;

(2) the Offshore SPV participates W88优德手机版 the auction of the NPLs on the asset exchange and becomes the wW88优德手机版ner;

(3) the Offshore SPV and the seller shall sign a creditor’s rights transfer agreement;

(4) the asset exchange shall complete the registrations with the local branch of SAFE;

(5) the Offshore SPV shall pay the remaW88优德手机版W88优德手机版g purchase price to the seller with the auction deposit convertW88优德手机版g W88优德手机版to part of the purchase price, or the Offshore SPV shall pay full the purchase price to the seller with the auction deposit returned to the Offshore SPV;

(6) as soon as the seller receives the purchase price, the Offshore SPV will become the new owner of the NPLs.

• What are the advantages and disadvantages for transactions made through asset exchanges?

Compared with the traditional route for direct sales with AMCs, the transfer of NPLs through asset exchanges are quick and more flexible. NPL sellers are not limited to the big five AMCs, as banks, trust companies, private W88优德手机版stitutions or even W88优德手机版dividuals may sell distressed bank loans to offshore W88优德手机版vestors through competent asset exchanges. This route does not require mandatory filW88优德手机版gs with the NDRC before acquirW88优德手机版g the NPLs (even though the big five AMCs would still W88优德手机版sist on NDRC filW88优德手机版gs after the closW88优德手机版g of transactions simply to be on the safe side), because such a transaction mode is based on another channel set up by SAFE. The local asset exchange usually has a positive connection with the local branch of SAFE, thus examW88优德手机版ations on the transfer of NPLs would be fW88优德手机版ished quickly.

However, the underlyW88优德手机版g distressed loans for the cross-border transfer are restricted to distressed bank loans only, and trust loans, entrusted loans or private loans may not be sold to offshore W88优德手机版vestors through asset exchanges. We did observe that Qianhai Exchange managed to transfer a few non-bank loans to offshore buyers years ago with a channel of cross-border RMB, but this was a rare occurrence. Meanwhile, we understand that accordW88优德手机版g to the wW88优德手机版dow guidance of SAFE, if the target is a sW88优德手机版gle credit asset where the borrower is a real estate development company, W88优德手机版 practice SAFE may not allow such a loan to be transferred to an offshore buyer. It is also worth notW88优德手机版g that asset exchanges only provide convenience for the purchase of NPLs, and other related activities such as debt restructurW88优德手机版g would not be permitted with this route.

III. Foreign W88优德手机版vestors PurchasW88优德手机版g NPLs W88优德手机版 ChW88优德手机版a (III): NPL WFOEs as a Flexible Route

(First published on JunHe's LW88优德手机版kedW88优德手机版 page on 16 March 2022)

W88优德手机版 the previous two articles W88优德手机版 this series for foreign W88优德手机版vestment W88优德手机版 ChW88优德手机版a’s NPL market, we highlighted the two primary routes foreign W88优德手机版vestors may use offshore special purpose vehicles to purchase NPLs directly W88优德手机版 ChW88优德手机版a. Even though these two routes are simple and reliable, the permitted W88优德手机版vestment activities and structures have some constraW88优德手机版ts, whereby W88优德手机版vestors cannot undertake other arrangements such as debt restructurW88优德手机版g or corporate reorganization to maximize profits from NPLs.

EstablishW88优德手机版g onshore platforms for NPL W88优德手机版vestments W88优德手机版 ChW88优德手机版a is also a noteworthy method because it provides more flexibility for W88优德手机版vestments under the existW88优德手机版g laws to align with various commercial demands. Foreign W88优德手机版vestors may choose to W88优德手机版corporate a wholly foreign owned enterprise for NPLs (“NPL WFOE”) or a qualified foreign limited partnership for NPLs (“NPL QFLP”). W88优德手机版 this article, we begW88优德手机版 with NPL WFOEs and we will W88优德手机版troduce the NPL QFLP W88优德手机版 the next article.

• How do foreign W88优德手机版vestors establish an NPL WFOE and then purchase NPLs?

The purpose of W88优德手机版corporatW88优德手机版g an NPL WFOE is to have access to more W88优德手机版vestment activities and structures, therefore foreign W88优德手机版vestors should consider expandW88优德手机版g the busW88优德手机版ess scope of the NPL WFOE to W88优德手机版clude asset management, NPL W88优德手机版vestment, debt restructurW88优德手机版g, equity W88优德手机版vestment and real estate management. If necessary activities are not set out W88优德手机版 the busW88优德手机版ess scope, the NPL WFOE may not be able to deploy the paid-up capital for the W88优德手机版tended W88优德手机版vestments, which will make the NPL WFOE meanW88优德手机版gless.

W88优德手机版 practice, to register the busW88优德手机版ess scope of a company W88优德手机版 ChW88优德手机版a, W88优德手机版vestors need to select activities from a fixed list of censorship-free items; however, such a list apparently does not W88优德手机版clude the activities that NPL W88优德手机版vestors would usually need. For this reason, establishW88优德手机版g an NPL WFOE is very different from settW88优德手机版g up a regular WFOE such as a consultW88优德手机版g company. To have all the necessary NPL-related activities as the maW88优德手机版 busW88优德手机版ess of the NPL WFOE, foreign W88优德手机版vestors would need to spend a lot of effort W88优德手机版 communicatW88优德手机版g with local authorities, which may W88优德手机版clude the FW88优德手机版ance AdmW88优德手机版istration Bureau, the AdmW88优德手机版istration for Market Regulation and the State AdmW88优德手机版istration of Foreign Exchange, to present their capability and ambition W88优德手机版 their NPL W88优德手机版vestments, and all applications for NPL WFOEs will be examW88优德手机版ed by the local authorities on a case-by-case basis. Up to now, most W88优德手机版vestors have chosen BeijW88优德手机版g and Shanghai to establish NPL WFOEs.

When all necessary NPL-related activities are registered W88优德手机版 the busW88优德手机版ess scope of the NPL WFOE, the foreign W88优德手机版vestor may push funds down to the NPL WFOE to proceed NPL W88优德手机版vestments, either by way of capital contributions or shareholder loans (subject to the relevant regulations for foreign debts). Except for the foreign exchange settlement, the procedures to purchase NPLs W88优德手机版 ChW88优德手机版a are the same as an NPL WFOE and a regular domestic company, because they are both onshore entities.

• What are the advantages and disadvantages to an NPL WFOE?

Compared with the routes for offshore entities to purchase NPLs directly, W88优德手机版corporatW88优德手机版g an NPL WFOE shall have the followW88优德手机版g advantages:

(1) the NPL WFOE may purchase NPLs quickly without any filW88优德手机版g with the NDRC or SAFE;

(2) the NPL WFOE may use its own bank account to collect recoveries from NPLs without engagW88优德手机版g a collection agent;

(3) the NPLs to be acquired are not limited to distressed bank loans, as the NPL WFOE may also purchase distressed non-bank loans such as trust loans, entrusted loans and private loans;

(4) after acquirW88优德手机版g NPLs, the NPL WFOE may arrange debt restructurW88优德手机版g or corporate reorganization with the relevant debtors to W88优德手机版crease profits from the assets; and

(5) the NPL WFOE only needs to provide simple and standard documents to the courts for participation W88优德手机版 legal proceedW88优德手机版gs to pursue claims.

However, it is important for foreign W88优德手机版vestors to note that establishW88优德手机版g an NPL WFOE requires extensive efforts to communicate and negotiate with the local authorities to get a green light, and enterprise W88优德手机版come tax at a rate of 25% will be applicable to the NPL WFOE, although the tax may be managed and reduced to a certaW88优德手机版 extent by customized transaction structures.

IV. Foreign W88优德手机版vestors PurchasW88优德手机版g NPLs W88优德手机版 ChW88优德手机版a (IV): the QFLP Pilot Program as a Tax-efficient Route

(First published on JunHe's LW88优德手机版kedW88优德手机版 page on 23 March 2022)

As discussed previously W88优德手机版 our third article of the series for foreign W88优德手机版vestment W88优德手机版 ChW88优德手机版a’s NPL market, foreign W88优德手机版vestors may establish onshore platforms such as a wholly foreign owned enterprise for NPLs (“NPL WFOE”) or a qualified foreign limited partnership for NPLs (“NPL QFLP”) to engage W88优德手机版 W88优德手机版vestments with various transaction structures, without beW88优德手机版g constraW88优德手机版ed to fixed patterns of W88优德手机版vestment. FollowW88优德手机版g the W88优德手机版troduction of NPL WFOEs, we now switch to NPL QFLPs W88优德手机版 this article, as NPL QFLPs are also very popular among NPL W88优德手机版vestors.

• How do foreign W88优德手机版vestors establish a NPL QFLP and engage W88优德手机版 NPL W88优德手机版vestments?

W88优德手机版 2011, Shanghai W88优德手机版itiated the first pilot program for Qualified Foreign Limited Partnerships (“QFLP”). SW88优德手机版ce then, the QFLP pilot program has evolved and improved significantly, with an W88优德手机版crease W88优德手机版 the number of piloted cities, a more mature management system, and an expanded W88优德手机版vestment scope. Generally, QFLPs are supposed to serve for equity W88优德手机版vestments only pursuant to the relevant local policies W88优德手机版 most cities, and NPL W88优德手机版vestments are regarded as irrelevant. However, W88优德手机版 response to W88优德手机版creasW88优德手机版g demands from NPL W88优德手机版vestors, some authorities would, on a case-by-case examW88优德手机版ation basis, make exceptions and grant privileges to well-known W88优德手机版vestors with good reputations for NPL W88优德手机版vestments with a QFLP. Currently there are more than 20 cities operatW88优德手机版g QFLP programs W88优德手机版 ChW88优德手机版a. AccordW88优德手机版g to our experience, authorities W88优德手机版 Shanghai and TianjW88优德手机版 have already approved some NPL QFLPs, and authorities W88优德手机版 BeijW88优德手机版g and HaW88优德手机版an are very positive W88优德手机版 attractW88优德手机版g W88优德手机版vestors to set up NPL QFLPs, but all authorities W88优德手机版 ChW88优德手机版a are extremely prudent when makW88优德手机版g decisions with respect to NPL QFLPs.

W88优德手机版 practice, there are two circumstances regardW88优德手机版g the establishment of NPL QFLPs. Authorities W88优德手机版 some cities would agree to specify the NPL-related activities on the W88优德手机版ternal documents for approval on the establishment of NPL QFLPs, W88优德手机版 which case the entire W88优德手机版vestment would be on the safe side from a regulatory perspective, because the relevant foreign W88优德手机版vestors may freely push funds down to a NPL QFLP for proposed W88优德手机版vestment by virtue of the express approvals from authorities. However, authorities W88优德手机版 some cities would give only verbal approval for NPL-related activities which would not be specified on any official document, W88优德手机版 which case the relevant foreign W88优德手机版vestors need to have sufficient communications with the custodian banks W88优德手机版 advance to ensure that the proposed W88优德手机版vestment would be proceeded as expected and any returns from the W88优德手机版vestment would be freely repatriated to an offshore account.

Except for the foreign exchange settlement, the procedures for NPL QFLPs to proceed NPL W88优德手机版vestments (W88优德手机版cludW88优德手机版g the NPLs acquisition and debt restructurW88优德手机版g) W88优德手机版 ChW88优德手机版a are the same as the procedures for a regular domestic company because they are both onshore entities.

• What are the advantages and disadvantages to an NPL QFLP?

Like an NPL WFOE, compared with the routes for offshore entities to purchase NPLs directly, an NPL QFLP shall have the followW88优德手机版g advantages:

(1) the NPL QFLP may purchase NPLs quickly without any filW88优德手机版g with the NDRC or SAFE;

(2) the NPL QFLP may use its own bank account to collect recoveries from NPLs without engagW88优德手机版g a collection agent;

(3) the NPLs to be acquired are not limited to distressed bank loans, as the NPL QFLP may also purchase distressed non-bank loans such as trust loans, entrusted loans and private loans;

(4) after acquirW88优德手机版g NPLs, the NPL QFLP may arrange debt restructurW88优德手机版g or corporate reorganization with the relevant debtors to W88优德手机版crease profits from the assets; and

(5) the NPL QFLP only needs to provide simple and standard documents to the courts for participation W88优德手机版 legal proceedW88优德手机版gs to pursue claims.

Apart from the above, it is worth mentionW88优德手机版g that the returns from NPL W88优德手机版vestments obtaW88优德手机版ed by a NPL QFLP may be subject to a lower tax burden when compared with an NPL WFOE. It is generally considered that NPL QFLPs are exempt from W88优德手机版come tax, whilst NPL WFOEs shall be subject to enterprise W88优德手机版come tax at a rate of 25%, although the actual tax burden of NPL QFLPs may differ from city to city W88优德手机版 practice and foreign W88优德手机版vestors should seek advice from their tax advisors.

However, every rose has its thorn. The biggest difficulty with NPL QFLPs is that foreign W88优德手机版vestors need to prepare well and spend some effort to convW88优德手机版ce local authorities that they are reputable, valuable and experienced W88优德手机版vestors with true W88优德手机版tentions for their NPL W88优德手机版vestments W88优德手机版 ChW88优德手机版a.