The SAC organized the drafting of the "Sponsor Representative Practice Standards (Consultation Draft)" (hereinafter referred to as the "Consultation Draft") on October 9 and is currently soliciting industry feedback. The Consultation Draft states that when sponsor representatives and other personnel engaged in sponsor business use artificial intelligence-assisted tools in their practice, they must strictly fulfill data confidentiality obligations, strengthen manual re-verification of AI-assisted tool outputs, and must not replace their own due diligence, prudent verification, and professional judgment with the output results of AI-assisted tools.
It is understood that this is the first time sponsor representative practice conduct has been codified as a standalone self-regulatory rule. The "Standards" comprise six chapters — General Provisions, Basic Practice Requirements, Basic Integrity Requirements, Sponsor Institution Management Responsibilities, Self-Regulatory Management, and Supplementary Provisions — totaling 31 articles. Previously, sponsor representative performance requirements were scattered across documents such as the "Securities Law," the "Administrative Measures for Sponsor Business of Securities Issuance and Listing," and the "Rules for Sponsor Business of Securities Companies"; this standalone codification represents a systematic consolidation.
Sponsor Representative Practice Standards Emphasize AI Usage Requirements
Why did the new rules specify this requirement? Judging from preliminary research, on one hand, large model tools are already widely used in investment banking project workpaper organization, industry information retrieval, and drafting initial inquiry responses; on the other hand, every statement in prospectuses and inquiry responses must ultimately be traced to "verification basis," and if tool-generated conclusions are not manually re-verified, the verification responsibility does not transfer with them. A securities firm insider said, "Whoever did the workpapers, whoever spoke the words — ultimately it falls on the signatory."