Article / 16 September 2015 at 2:32 GMT

No home for China shares in a fair-priced portfolio Team / Saxo Bank
  • Shanghai's 30% decline has seen twice the value of the ASX wiped out
  • The “big four” auditors have to license their brand out to local affiliates
  • Not even US-listed firms are subject to auditing, an exemption the SEC allows
  • There are safer ways of playing China's middle class without transparency issues
By Roger Montgomery

The year to June witnessed enormous variation in sharemarket returns. The Australian All Ordinaries Index recorded a miserly 1.3% return, excluding dividends. The Shanghai Composite Index was easily the best performing major market with a return of 108.8%.

That excitement, which saw the Chinese market up 152% at its peak, was driven by a lot of leverage (that is, investors borrowing to finance their share investments). There are plenty of individual shares selling on nose-bleeding multiples.

The 30% decline in the past month has seen $3.2 trillion of value, or more than two times the total value of the Australian sharemarket, wiped out. Given most small Chinese investors who undertake margin lending joined the market near its peak, there is a fear this decline will transmit into the real economy.

Making matters worse, about one-quarter of the companies, representing one third of the market capitalisation (and listed on the main exchanges in Shanghai and Shenzhen) have had their stock suspended, something usually reserved for significant imminent announcements.

Surety needed in investment

The “risk off” bet (the decision of many Chinese investors to sell at the same time) has translated into a recent sharp decline in iron ore, down 26% to about $US45/tonne; crude oil, down 12% to $52/barrel and copper, down 7% to $2.44/lb.

The objective of my global fund is to find a handful of high-quality companies, with good prospects at a discount to their estimated intrinsic value, and if there are insufficient companies that appeal, then we allow the cash component of the portfolio to build.

Bullish, volatile or simply unknown? The Shanghai Composite's performance has been
nothing less than crazy - how could we know real share values? Photo: iStock

To run such a fund you need to be absolutely sure of the numbers that you work with. Excess volatility also does not make the job any easier. Some investors will take heart at the ‘rebound’ we saw at the end of the week in the Chinese share market with a 6%jump in a single session.

But the fund does not, and is unlikely to own, any Chinese-listed companies.

The issue I have is one of transparency and that has a lot to do with the audit process and the hurdles foreign auditors face when trying to assess Chinese companies. Such financial and business information has been categorised by the Chinese government as state secrets, so cannot be turned over to foreigners.

The “big four” auditing firms do not operate in mainland China. Instead, they essentially license their brand name to local affiliates. Under US law, all major auditors must undergo regular inspections by the Public Company Accounting Oversight Board (PCAOB).

Yet the PCAOB is not allowed by the Chinese government to inspect the local Chinese affiliates of the big four auditing firms. It cites national security reasons. Therefore, all US-listed Chinese firms appear to be in breach of the Securities Exchange Act.

SEC caves in

The Securities and Exchange Commission, however, basically has caved in to Beijing’s refusal to turn over such corporate information to US regulators. The SEC had the right to de-list all Chinese companies from US exchanges for being in breach of the Securities Exchange Act. It chose not to.

Chinese accounting expert Paul Gillis, from the Guanghua School of Management at Peking University, sums up the situation nicely: “Today we have different rules for Chinese companies that list in the US than we have for others. Not only is the SEC dependent on Chinese regulators to decide what documents they can see, the PCAOB remains unable to conduct inspections of auditors.”

In Australia, we have the Corporations Act 2001, which sets out the laws dealing with companies in Australia. Section 310 of the act states: “The auditor: (a) has a right of access at all reasonable times to the books of the company, registered scheme or disclosing entity; and (b) may require any officer to give the auditor information, explanations or other assistance for the purposes of the audit or review.”

So what would an Australian auditor do if it were faced with the task of auditing a Chinese company?

Of course there are always opportunities in China, but there are safer ways of playing the growing middle class - and you don’t need to suffer the knee-trembling volatility or poor transparency of investing directly into a Chinese-listed company.

Roger Montgomery
is founder and chief information officer of the Montgomery Fund.

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