Dual listings are difficult because each exchange has different sets of regulatory requirements related to disclosure, timing, and underwriting practices. These issues can become especially complicated in a large offering.

So Chen and his team began working under what he calls some of “the most challenging circumstances I have seen” so AgBank’s IPO could launch in both markets. By April 2010, the bank had lined up ten lead underwriters, a record number–four for Shanghai and six for Hong Kong. It would fall to the Davis Polk lawyers to manage the various opinions of the underwriters and smoothly incorporate them into the prospectus.

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