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Comment Letter on Nasdaq’s Proposed Additional Initial Listing Criteria for Companies Primarily Operating in China

The Council of Institutional Investors (CII) submitted a comment letter backing Nasdaq’s proposed rule that adds initial listing criteria for Chinese micro‑cap companies, including a $25 million minimum proceeds requirement. CII applauds the effort to curb abnormal trading in the smallest Chinese stocks but urges the rule’s scope be broadened to cover micro‑caps incorporated in the Cayman Islands and other high‑risk jurisdictions. The letter cites the opaque VIE structures and weak Cayman corporate‑law protections that have facilitated fraud and investor losses. By expanding the criteria, CII aims to safeguard the roughly $5 trillion of assets its members manage.