There are three tiers to listing via ADRs, the highest one gives access to capital markets, and based on some of the talk, it seems the requirements they are trying to meet, are the ones for the top tier. (Full compliance with SEC reporting).
When they list, does the sponsoring bank have to buy on market on the asx for the shares they hold in proxy for the ADRs they list on the NASDAQ?
Doubt it for a small company. Imagine trying to buy even 5% of the float on market!
Therefore, they issue new shares to cover the needs of the ADRs on the DAQ. = IPO
This is just my first principles take on it.
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