If the appropriate accounting firm discovers in providing auditing services that the accounting information provided by the Chinese company listed in the U.S. might involve state secrets but is not approved yet, it should also remind the company listed in the U.S. of the appropriate legal risks in a timely manner.

　　3. Appropriate accounting firms should ask the state archives authorities to interpret the applicable provisions of the Archives Law in a suitable manner to define which auditing working papers are owned by the state and which are archives “whose preservation is of value to the state and society”， and if the business cooperation pattern between domestic and overseas accounting firms involves the exit of archives. Once these questions have been clarified, there will be clear legal guidance for Chinese companies listed in the U.S. and appropriate accounting firms to procure the legal obligation of guarding archives.

　　4. Chinese companies listed in the U.S. and appropriate accounting firms should amend the confidentiality clause of the auditing services agreement. Considering there are certain legal risks in providing for exceptions to the non-disclosure obligation in the auditing services agreement itself, Chinese companies listed in the U.S. and appropriate accounting firms should communicate actively to eliminate the concerns of the CSRC.

　　On one hand, the auditing services agreement may specify that “accounting firms shall abide by the law of the PRC and obtain the lawful approval of the competent authorities of the PRC in providing auditing working papers or other information to the outside” in order to show the respect to the laws and regulations of the PRC; on the other hand, this　may be inappropriate if the PCAOB and other overseas regulatory authorities have the authority to require registered accounting firms to provide auditing working papers and other appropriate information, etc., which will neither affect the rights and obligations of the parties nor incur any legal risk.