Author：sherryIn the IPO review process, bank statement verification is an extremely important part, the main purpose of which is to find out whether the issuer has the problem of extracorporeal circulation of funds or the occupation of funds by related parties that have not been recorded. For the internal bank statement verification of the issuer, it is necessary to verify the bank statements of all bank accounts of all entities within the scope of consolidation, but for the scope of external bank statement verification, according to the "5-15 Fund Statement Verification" in the "Guidelines for the Application of Regulatory Rules - Issuance No. 5" guidelines of the CSRC, it is only agreed that the controlling shareholders, actual controllers, directors and supervisors of the issuer, Executives and other relevant personnel, and the corresponding scope is not clearly indicated. In practice, we generally check the bank statements of the controlling shareholder and other legal entities under its control, the actual controller and his or her spouse and other legal entities under their control, the main relatives of the actual controller serving in the issuer, directors, supervisors, senior executives, and key financial personnel such as the person in charge of accounting, the person in charge of the accounting institution, the cashier, etc. In different cases, the regulator may require the scope of verification to be expanded according to the actual situation of the enterprise, for example, Qiangbang New Materials requires that the main sales personnel be covered;Lijiexun requires the sales personnel and procurement personnel of the actual controller;Tianji Technology's requirements cover key personnel in the purchasing department and sales departmentLongjiang Wagyu requirements cover purchasing managers and cashiers of affiliated companies. In some cases, it is even required to verify the actual controller's full-time drivers and personal assistants, as well as the issuer's departed personnel. In practice, in addition to the scope of basic verification, the scope and focus of verification are different in each case. In general, the anomalies that need to be expanded can be divided into two categories, one is that abnormal transactions are found in the verification of the flow within the basic scope, and it is not only necessary to increase the verification of the bank statements of individuals and companies with abnormal bank accounts, but also to consider whether to expand the sample. The second category is abnormal risk matters in the IPO review process. According to the "5-15 Verification of Capital Flows" in the Guidelines for the Application of Regulatory Rules - Issuance No. 5 of the CSRC's "Guidelines for the Application of Regulatory Rules - Issuance No. 5", it is clearly pointed out that when there are some abnormal risk matters, it is necessary to consider expanding the scope of capital flow verification. The discovery of these anomalies often requires us to maintain professional skepticism and professional sensitivity to the issuer's financial data. This article summarizes the ideas of some regulators on the discovery of abnormal situations in flow verification by sorting out the feedback questions and answers of various sectors in the recent period, combined with the abnormal situations mentioned in the guidelines of the CSRC. From the summarized cases, we can get some inspiration from the perspective of the regulator's thinking, and further think about how to detect anomalies. In the IPO review, the anomalies we find are often a small "vine" in the vine, and it is possible to find the final "melon" only by continuously expanding the scope of verification along the vine. OneThe issuer's distribution model accounts for a relatively high or significantly higher proportion than that of companies in the same industry, and the gross profit margin of distribution is quite abnormalFor issuers that adopt the distribution model and account for a relatively high proportion, the verification of their flow is a procedure that the regulator focuses on, and if there are abnormal financial indicators, it is more necessary to consider whether to expand the scope of fund flow verification. The abnormal indicators mentioned in the feedback Q&A are: 1During the reporting period, the sales scale or unit price of some dealers**;2.During the reporting period, there were large differences in the unit price and gross profit margin of different distributors of the issuer;3.Dealers have a large inventory at the end of the period;4.During the reporting period, the main distributors did not act as distributors of similar products of comparable companies at the same time, and the proportion of distributors' procurement of issuers' products in the procurement cost of similar products was generally high5.There are dealers who cooperate with the issuer in the year of establishment and have a large purchase amount;6.During the reporting period, the issuer made certain adjustments to the credit policy of its major dealer customers7.The registered capital of the issuer's major distributors is low, and some dealers have fewer employees;8.Some dealers are overseas, and the proportion is relatively high. In addition to the issues mentioned in the above inquiry, for the distribution model, we also need to pay attention to whether there are large-scale changes in the dealer, the withdrawal and accession, the new dealers at the end of the period, and the potential affiliation if the dealer's registered place is in the issuer's registered place. 
IIThere are significant abnormal changes in the issuer's gross profit margin, period expense ratio, net sales profit margin and other indicators in each period, or there are major inconsistencies with companies in the same industry;The analysis of financial indicators is often based on comparisons with historical conditions and comparable companies in the same industry. In addition, there are some abnormal situations that we need to pay attention to, such as the possibility of extracorporeal circulation of funds in the case of divergence between cash flow from operating activities and net profit, high deposits and loans, abnormal growth of cash flow from investment activities and exceeding the net cash flow of enterprises. The cases of abnormal indicators mentioned in recent inquiry cases are as follows:1Some of the details of sales expenses and R&D expenses have been declining year by year and the proportion is unreasonable, such as Haisheng tungsten industry;2.The turnover rate of accounts receivable is significantly higher than that of comparable companies, and the gross profit margin level is much higher than that of the same industry, such as Zhiyuan Electronics. 
IIIThere are irregularities in operating costs and procurement;During the declaration period, if there is an abnormality in the change of operating costs, or an abnormality in the purchase unit price, and the change does not conform to the laws of the industry, it may be that there is an in vitro disbursement fee. In the case of inquiry, the following cases of concern were raised for anomalous pointers:1The line items of the main business cost change abnormally, such as the proportion of manufacturing expenses in the main business cost has increased year by year;2.There is a difference between the purchase unit price of the main raw materials and the average market price, and some varieties are quite different;3.The change of ** business is large, and some ** business will become the issuer ** business in the year of establishment or the following year;4.**The business is controlled by a former employee of the issuer;5.The unit material cost, unit consumption, and unit working hours of some major raw materials have decreased year by year. 
FourthAt the end of the period, there are large projects under construction and fixed assets and there are abnormal situations;In many cases of financial fraud, many listed companies use projects under construction, fixed assets and other subjects to transfer funds and realize the circulation of funds in vitro. When the following abnormal indicators are found, we should maintain professional suspicion, confirm the authenticity of the construction in progress and fixed assets, and confirm the reasonableness of the relevant project expenditure amount in combination with the flow of funds related to the issuer's fixed assets and construction in progress, and the abnormal indicators are as follows:1There are long-term projects under construction that have not been carried forward;2.During the reporting period, the balance of fixed assets and projects under construction was significantly larger3.The main engineering contractor has an affiliated relationship with the issuer, and there are a number of lawsuits and disputes;
FiveThere are material irregularities in the issuer's fund management. For example, the related party mentioned in the inquiry case pays wages and pays social security provident fund on behalf of othersDuring the reporting period, the company had the situation of employees collecting payment on behalf of employees. 
SixIssuersThere is an exception in the related party。If the issuer has more related parties or has more related party transactions with the issuer during the reporting period, the difficulty of verifying the corresponding capital flow will increase, and the corresponding risk will also increase. The anomalies mentioned in the inquiry case are:1There are many enterprises controlled by actual controllers and their relatives, with significant influence, or as directors or senior managers;2.During the reporting period, the issuer had a large number of related parties deregistered;3.During the reporting period, the issuer and its affiliates had capital transactions with a number of ** merchants of the issuer and their affiliates;4.There are multiple instances in which the issuer purchases assets from related parties.
SevenVerification of the flow of online business. For today's increasingly online sales business model, in addition to performing other services to confirm the authenticity of sales, such as verifying the operating data on the system, conducting data analysis, sampling interview tests, etc., it is also necessary to verify the directors, supervisors and senior executives of the issuer, the actual controller, directors, supervisors and senior executivesE-commerce businessand the cashier shall be in charge of the bank statements during the reporting period, verify the transaction background, reasons and reasonableness of the large amount of transactions, and prevent the provision of funds to relevant personnel to complete the business of e-commerce platform swiping.
EightThere are large dividends during the reporting period. If there is a large amount of dividends during the reporting period, the sponsor should explain the specific purpose of the issuer's dividends and the verification measures taken by the issuer during the reporting period, as well as the flow of funds, and whether there is a substantial flow to the issuer's customers and merchants. Feedback Q&A cases include Changchun Stirring, Yingshuang Technology, Xinguangyi, Huanya Technology, etc.