According to the Complaint, Wins Finance Holdings Inc., through its subsidiaries, purports to provide financing solutions for small and medium enterprises in the People’s Republic of China. The Company purports to offer financial guarantees, as well as financial leasing, advisory, consultancy, and agency services in Jinzhong City, Shanxi Province, and Beijing. In 2014, Wins entered into a RMB 580 million credit arrangement with Guohong. By the terms of the Guohong Loan, repayment to Wins was due in October 2019. In September 2017, Wins engaged CZD as its independent registered public accounting firm after dismissing its previous accounting firm.

The Complaint alleges that during the Class Period, Defendants made false and/or misleading statements, as well as failed to disclose material adverse facts about the Company’s business, operational and compliance policies. Specifically, the Complaint alleges Defendants made false and/or misleading statements and/or failed to disclose that: (i) the ultimate repayment of the RMB 580 million Guohong Loan was highly uncertain; (ii) nonpayment of the Guohong Loan would have a significant impact on the Company’s financial and operating condition; (iii) weaknesses in Wins’s internal control over its financial reporting persisted despite the Company’s repeated assurances to investors that it was taking steps to remediate these weaknesses; (iv) the foregoing issues, among others, made the resignation of Wins’s independent auditor foreseeably likely; and (v) as a result, the Company’s public statements were materially false and misleading at all relevant times.