Capital Markets Advisory
For founders and CFOs of China-based and cross-border companies evaluating U.S. market access under Nasdaq Rule 5210(l) and the current enforcement climate.
The $25 million standard
The $25 million public-offering standard for direct Nasdaq listings by companies principally operating in China is now operative. Plans written for the old door no longer fit the new one.
The transfer route is codified
The OTC-to-Nasdaq transfer route is now codified, with a one-year seasoning period. For many companies it is the realistic pathway, provided the seasoning year is used deliberately.
Scrutiny at record levels
Enforcement and listing-review scrutiny of cross-border issuers is at record levels. Preparation quality, gatekeeper selection, and disclosure discipline now decide outcomes.
Services
A structured readiness evaluation against the operative U.S. rules and the client's venue alternatives: U.S., Hong Kong, and A-share. The output is a candid assessment of where the company stands and which pathways are realistically open.
A gap analysis and preparation plan for companies targeting the $25 million direct-listing standard. We benchmark the company against the standard's requirements and map the work needed to close each gap.
Entry planning, tier selection, and disclosure-infrastructure readiness for the OTC markets. We coordinate the licensed market-maker, auditor, and counsel workstreams so each moves in the right sequence.
A twelve-month disclosure, governance, and shareholder-base development program for companies on the OTC-to-Nasdaq transfer pathway. The seasoning year is an asset when it is planned, and a lost year when it is not.
Application readiness, float and governance benchmarking, and sequencing of China-side filing obligations, executed with the client's licensed advisors. We prepare the plan; the licensed professionals carry it out.
Structured diligence on underwriters, auditors, and counsel using public regulatory records. We help clients evaluate and select the licensed firms whose track records fit the mandate, and coordinate them once engaged.
Engagement model
Engagements are fixed-fee or retainer-based strategic advisory, scoped in writing before work begins. Fees are for advisory work (assessment, planning, benchmarking, and coordination) and are never contingent on any transaction, listing, or financing outcome.
Every engagement begins with a confidential pathway-review conversation to define the question. If the honest answer is that a pathway is not open, that is the advice.
Direct booking — coming soon
CW&A is a strategic advisory firm. We do not underwrite, place, or offer securities, and we do not provide investment, legal, tax, or accounting advice. Execution is carried out by the licensed broker-dealers, auditors, and counsel we help clients select and coordinate.
The $25 Million Wall
Lead brief
A structured, interactive readiness assessment built on the same diagnostic the book describes: where the company stands against the operative standards, which pathway assumptions hold, and what the next twelve months should look like. Complete it and receive a written readiness brief.
Interactive assessment — coming soon
Email delivery for the Readiness Brief is being commissioned. Capture is temporarily unavailable so requests cannot be lost before the receiving address is active.