Csc Upshot Ventures Management, LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I

A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
7255689
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SHAN, XIANGSHUANG
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CHINA SCIENCE & MERCHANTS
INVESTMENT MANAGEMENT
GROUP CO LTD
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SHENZHEN OFFICE OF CHINA SECURITIES REGULATORY COMMISSION
2.
Principal Sanction:
Reprimand
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/29/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
(2017)61; (2017)62
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product

Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CHINA SCIENCE & MERCHANTS INVESTMENT MANAGEMENT GROUP CO. LTD. ("CSM") WAS LISTED ON CHINA'S NATIONAL EQUITIES EXCHANGE AND
QUOTATIONS IN 2015. IN CONNECTION WITH CSM'S OBLIGATIONS AS A PUBLIC COMPANY UNDER THE APPLICABLE CHINESE LAW, SHENZHEN OFFICE
OF CHINA SECURITIES REGULATORY COMMISSION ("CSRC SHENZHEN") ALLEGED THAT (I) CERTAIN DISCLOSED RELATED PARTY TRANSACTIONS
ENTERED INTO BY CSM OR ITS AFFILIATES CONSTITUTED OCCUPATION OF FUNDS, AND (II) CSM FAILED TO DISCLOSE CERTAIN OTHER TRANSACTIONS
ENTERED INTO BY CSM THAT CONSTITUTED OCCUPATION OF FUNDS. SHAN XIANGSHUANG, AS THE CONTROLLING SHAREHOLDER, CONTROL PERSON
AND CHAIRMAN OF BOARD OF CSM, FAILED TO TAKE THE NECESSARY STEPS TO PREVENT THE FOREGOING OCCUPATION OF FUNDS AND TO CAUSE CSM
TO FULFILL ITS DISCLOSURE OBLIGATION.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
09/29/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
CSRC SHENZHEN (I) ORDERED CSM TO TAKE FOLLOW-UP CORRECTIVE STEPS AND (II) ISSUED A WARNING LETTER TO CSM AND SHAN
XIANGSHUANG REPRIMANDING THEIR BEHAVIORS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CSRC SHENZHEN REQUESTED CSM TO, AND REQUESTED SHAN XIANGSHUANG TO CAUSE CSM TO (I) IMPROVE ITS ASSETS AND MANAGEMENT
CONTROL, (II) TAKE NECESSARY STEPS TO PREVENT OCCUPATION OF FUNDS BY SHAREHOLDERS AND OTHER RELATED PARTIES IN THE FUTURE,
AND (III) ENSURE THE QUALITY AND SUFFICIENCY OF ITS INFORMATION DISCLOSURE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CSM HAS RESTORED AND CLEANED UP ALL OF THE OCCUPATION OF FUNDS AS SPECIFICALLY MENTIONED IN THE CSRC'S DECISION AS OF AUGUST 11,
2016, TOOK NECESSARY STEPS TO PREVENT OCCUPATION OF FUNDS BY SHAREHOLDERS AND OTHER RELATED PARTIES IN THE FUTURE, COMMITTED
TO (A) PROVIDE INTERNAL TRAINING OF RELEVANT CHINESE LAWS AND REGULATIONS TO ITS BOARD AND EXECUTIVE OFFICERS, (B) REQUEST ITS
PERSONNEL TO COMPLY WITH RELEVANT CHINESE LAWS AND REGULATIONS, AND (C) IMPROVE ITS MANAGEMENT AND CONTROL SYSTEMS OVER
INFORMATION DISCLOSURE, AND MADE A PUBLIC ANNOUNCEMENT REGARDING THE FOREGOING ON SEPTEMBER 29, 2017.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File

with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
7255689
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SHAN, XIANGSHUANG
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CHINA SCIENCE & MERCHANTS
INVESTMENT MANAGEMENT
GROUP CO LTD
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SHENZHEN OFFICE OF CHINA SECURITIES REGULATORY COMMISSION
2.
Principal Sanction:
Undertaking
Other Sanctions: 
REPRIMAND
3.
Date Initiated (MM/DD/YYYY): 
11/11/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:

(2015)40; (2015)41
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CHINA SCIENCE & MERCHANTS INVESTMENT MANAGEMENT GROUP CO. LTD ("CSM") WAS LISTED ON CHINA'S NATIONAL EQUITIES EXCHANGE AND
QUOTATIONS IN 2015. IN CONNECTION WITH CSM'S DISCLOSURE OBLIGATIONS AS A PUBLIC COMPANY UNDER THE APPLICABLE CHINESE LAW,
SHENZHEN OFFICE OF CHINA SECURITIES REGULATORY COMMISSION ("CSRC SHENZHEN") ALLEGED THAT CSM FAILED TO FULLY DISCLOSE CERTAIN
INFORMATION TO MEDIA PRIOR TO MAKING THE PUBLIC DISCLOSURE, AND FAILED TO CORRECT CERTAIN INFORMATION PUBLISHED ON MEDIA. CSRC
SHENZHEN ALSO ALLEGED THAT SHAN XIANGSHUANG, AS THE CHAIRMAN OF BOARD AND GENERAL MANAGER OF CSM, SHALL BE RESPONSIBLE FOR
CSM'S FOREGOING ACTIVITIES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
11/16/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
CSRC SHENZHEN (I) ORDERED CSM TO TAKE FOLLOW-UP CORRECTIVE STEPS AND (II) ISSUED A WARNING LETTER TO SHAN XIANGSHUANG
REPRIMANDING HIS BEHAVIORS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CSRC SHENZHEN REQUESTED CSM TO (I) IMPROVE ITS INFORMATION DISCLOSURE MECHANISM, (II) STANDARDIZE ITS PROCEDURES IN
CONNECTION WITH TAKING MEDIA INTERVIEWS AND PUBLISHING INFORMATION IN THE MEDIA, AND (III) SUBMIT A RECTIFICATION REPORT
RELATING TO CSM'S PLAN TO MAKE RELEVANT CORRECTIONS AND IMPROVEMENTS WITH 15 BUSINESS DAYS UPON THE RECEIPT OF THIS
DECISION.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CSM SUBMITTED THE RECTIFICATION REPORT WITHIN THE 15 BUSINESS DAYS PERIOD, COMMITTED TO (A) PROVIDE INTERNAL TRAINING OF RELEVANT
CHINESE LAWS AND REGULATIONS TO ITS BOARD AND EXECUTIVE OFFICERS, (B) REQUEST ITS PERSONNEL TO COMPLY WITH RELEVANT CHINESE
LAWS AND REGULATIONS, AND (C) IMPROVE ITS MANAGEMENT AND CONTROL SYSTEMS OVER INFORMATION AND DISCLOSURE, AND MADE A PUBLIC
ANNOUNCEMENT ON NOVEMBER 16, 2015 TO APOLOGIZE FOR THE VIOLATION OF RELEVANT CHINESE LAWS AND REGULATIONS AND TO DISCLOSE THE
CSRC SHENZHEN'S DECISION AND CSM'S CORRECTIVE PLAN.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)

( )
( )
( )
( )
( )
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
7255689
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SHAN, XIANGSHUANG
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SHENZHEN OFFICE OF CHINA SECURITIES REGULATORY COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/30/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
(2016)5
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Other
Other Product Types: 
INVESTMENT IN EQUITY SECURITIES OF A PRC ISSUER LISTED ON CHINEXT
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CHINA SCIENCE & MERCHANTS INVESTMENT MANAGEMENT GROUP CO. LTD. ("CSM") WAS LISTED ON CHINA'S NATIONAL EQUITIES EXCHANGE AND
QUOTATIONS IN 2015. SHENZHEN OFFICE OF CHINA SECURITIES REGULATORY COMMISSION ("CSRC SHENZHEN") ALLEGED THAT CHINA SCIENCE
HUITONG EQUITY INVESTMENT FUND ("HUITONG"), A WHOLLY-OWNED SUBSIDIARY OF CSM, FAILED TO DISCLOSE ITS CONTINUOUS PURCHASE AND
HOLDING OF SECURITIES OF NETAC TECHNOLOGY CO., LTD. ("NETAC") WHEN ITS SHAREHOLDING IN NETAC REACHED 5%. SHAN XIANGSHUANG, AS
THE LEGAL REPRESENTATIVE OF HUITONG, IS RESPONSIBLE FOR HUITONG'S FAILURE TO DISCLOSE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
01/26/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 28,570.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
CSRC SHENZHEN ORDERED HUITONG TO CORRECT ITS VIOLATION AND ISSUED A WARNING LETTER REPRIMANDING THE BEHAVIORS OF HUITONG
AND SHAN XIANGSHUANG.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CSRC SHENZHEN ORDERED HUITONG TO CORRECT ITS VIOLATION BY REPORTING AND MAKING PUBLIC DISCLOSURE OF ITS ABOVE 5%
SHAREHOLDING IN NETAC WITHIN 3 DAYS UPON RECEIPT OF CSRC SHENZHEN'S DECISION, ISSUED A WARNING LETTER TO SHAN XIANGSHUANG
REPRIMANDING HIS BEHAVIORS, AND IMPOSED A TOTAL FINE OF RMB 3,900,000, AMONG WHICH, RMB 300,000 (APPROXIMATELY, $28,570 USD)
WAS IMPOSED UPON SHAN XIANGSHUANG.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
HUITONG MADE THE REQUISITE REPORTING AND DISCLOSURE RELATING TO ITS ABOVE 5% SHAREHOLDING IN NETAC, HUITONG AND SHAN
XIANGSHUANG PAID THE MONETARY FINE, AND CSM MADE A PUBLIC ANNOUNCEMENT ON JANUARY 26, 2017 TO APOLOGIZE FOR THE VIOLATIONS BY
HUITONG AND SHAN XIANGSHUANG AND COMMIT TO (A) PROVIDE INTERNAL TRAINING OF RELEVANT CHINESE LAWS AND REGULATIONS TO ITS BOARD
AND EXECUTIVE OFFICERS, (B) REQUEST ITS PERSONNEL TO COMPLY WITH RELEVANT CHINESE LAWS AND REGULATIONS, AND (C) IMPROVE ITS
MANAGEMENT AND CONTROL SYSTEMS OVER INFORMATION DISCLOSURE.