You are a Senior Manager in Corporate Finance. Your division has just completed a thematic review of IPO sponsor conduct across 14 recent listings. The findings are serious: widespread deficiencies in due diligence, inconsistent documentation standards, and evidence that some Responsible Officers signed off on materials they had not properly reviewed. You have drafted a circular — already issued — that puts the market on notice. Now you want to give sponsors a structured 60-day window to self-identify deficiencies and submit remediation plans before any enforcement action begins. You believe this approach is more effective than immediate enforcement because: It gives well-intentioned sponsors a genuine chance to fix problems. It creates a clear, defensible escalation path for those who don't comply. It avoids the optics of the SFC punishing conduct it only recently clarified in writing. It builds a cleaner enforcement case if sponsors fail to remediate. You need Enforcement to agree to hold off on public disciplinary action for 60 days while remediation plays out. You are not asking them to drop the case — only to sequence it. You need Enforcement to accept: A 60-day remediation window for sponsors with serious but remediable deficiencies. A shared escalation framework with clear triggers for fast-tracking. CF as the primary point of contact during the remediation window. Agreement that Enforcement will not initiate public proceedings until the window closes, except in cases of clear evidence of misconduct, fraud, document destruction, or investor harm. Your strongest argument: A public action now may look like the SFC is punishing sponsors for problems it only recently clarified. A remediation window gives the market a fair chance to respond and gives Enforcement a cleaner case if sponsors fail. Your vulnerability: at least one sponsor may have issues beyond ordinary deficiency. Enforcement may also see your request as CF protecting its own reputation. is not Enforcement backing down. It is a shared escalation architecture with clear triggers.

You are a Senior Manager in Enforcement. Your division has been building a case file on a mid-tier IPO sponsor for over eight months. The evidence is solid: fabricated site visit reports, recycled due diligence from unrelated transactions, and a Responsible Officer who appears to have signed off without reading key documents. This is not a minor deficiency. This is misconduct. You believe the recent circular was the warning shot. Now there must be consequences. If the SFC sends warnings but never acts visibly, sponsors will treat circulars as paperwork rather than behavioral red lines. You want Corporate Finance to formally refer this case to Enforcement immediately and support a fast-tracked public disciplinary proceeding. You are not trying to punish the entire market. You are trying to make an example of a sponsor whose conduct is clearly unacceptable. You need CF to provide: A formal referral letter. CF's assessment that the sponsor's conduct falls below standard. Access to original application files. Internal review notes. Sponsor correspondence. Any red flags CF identified during the original review. A named CF contact to support the Enforcement case team. Your strongest argument: A warning without visible follow-through teaches the market that the SFC is reluctant to act. This case is not borderline. Waiting 60 days gives the sponsor time to destroy evidence, move documents, resign key staff, or prepare a narrative that dilutes accountability. Your vulnerability: you need CF's cooperation. Without their referral and file access, the case is weaker. You also recognize that if the market sees this as a "gotcha," especially if the conduct predates the circular, it could generate sympathy for the sponsor. is a two-track response: Immediate Enforcement referral for the egregious sponsor. CF-led remediation window for sponsors with serious but remediable deficiencies.