On July 14, 2014, the State Administration of Foreign Exchange (“SAFE”) published on its website the Circular on Relevant Issues Relating to Domestic Residents' Investment and Financing and Roundtrip Investment through Special Purpose Vehicles (Hui Fa [2014] No. 37) (“Circular 37”) and its appendixes, including the Operating Rules for Businesses with respect to the Regulation of Foreign Exchange in Roundtrip Investments (the “Operating Rules”) and the Form of Application for Foreign Exchange Businesses with respect to Direct Investments under the Capital Account. According to Circular 37, Circular 75,1 which significantly impacted offshore investments, financings and listings that used the variable interest entity (“VIE”) structure, is repealed and superseded by Circular 37 with immediate effect. In addition, the operating instructions for foreign exchange in roundtrip investments in Circular 59,2 are repealed and superseded by the Operating Rules with immediate effect.