New York Paris Northern California Madrid Washington DC Tokyo São Paulo Beijing London Hong Kong James C. Lin Partner Resident Hong Kong Partners Davis Polk & Wardwell 852 2533 3368 tel William F. Barron* Gerhard Radtke* Hong Kong Solicitors 852 2533 1768 fax Bonnie Chan* Martin Rogers † The Hong Kong Club Building
[email protected] Karen Chan † Patrick S. Sinclair* 3A Chater Road Paul K. Y. Chow* † Miranda So* Hong Kong James C. Lin* James Wadham † Hong Kong Solicitors * Also Admitted in New York † Also Admitted in England and Wales August 29, 2019 Re: Application for Designation of the Taipei Exchange Main Board and Taipei Exchange Bond Market as a “Designated Offshore Securities Market” Michael Coco, Chief Office of International Corporate Finance Division of Corporation Finance United States Securities and Exchange Commission 450 Fifth Street. N.W. Washington, DC 20549 Dear Mr. Coco: We are writing to the United States Securities and Exchange Commission (the “SEC” or the “Commission”) on behalf of the Taipei Exchange (the “TPEx”) to apply for the classification of a “designated offshore securities market” for purposes of Regulation S (“Regulation S”) under the U.S. Securities Act of 1933, as amended, for (i) the portion of the TPEx known as the Taipei Exchange Main Board (the “TPEx Main Board”) and (ii) the portion of the TPEx known as the Taipei Exchange Bond Market (the “TPEx Bond Market” and together with the TPEx Main Board, the “TPEx Platforms”). Designation is being sought in order to assist market participants to the TPEx Platforms who are eligible for the safe harbor provision provided by Rule 904 of Regulation S to satisfy the requirements specified in that rule when reselling securities “in, on or through the facilities of” the TPEx Platforms.