Apr. 30, 2021
Dear Sir/Madam,
We are submitting the comments in response to the Commission's interim final amendments ("Interim Final Amendments") to reflect the disclosure requirements of the Holding Foreign Companies Accountable Act ("HFCA Act") (File No. S7-03-21) on behalf of China Southern Airlines Company Limited (NYSE: ZNH) as follows:
The HFCA Act and the Interim Final Amendments may bring adverse effect to the interests of global investors of the “Commission-Identified Issuers”. The HFCA Act and the Interim Final Amendments do not take into account the reality of many issuers which are listed on multiple stock markets. Issuers listed on multiple stock markets are required to comply with laws and regulations of multiple markets, and they are required to protect the interests of global investors. If there are any conflicts in relevant laws and regulations of different stock markets, the conflicts should be coordinated and resolved through regulators’ cooperation. Compulsory delisting of an issuer will bring adverse effect to the interests of global investors, including U.S. investors.
Thank you for considering these comments.
Best regards,
Jingtian & Gongcheng LLP
on behalf of China Southern Airlines Company Limited