Pursuant to Clause 3, Article 2 of Circular 107/2016/TT-BTC, the organization issuing underlying securities is the organization issuing securities as the underlying asset of warrants.

Pursuant to Clause 4, Article 13 of Circular 107/2016/TT-BTC regulating trading activities and payment of warrant transactions of investors as follows:

“Trading activities and payment for warrant transactions of investors

1. Warrants are traded through the trading system of the Stock Exchange according to the instructions in the regulations of the Stock Exchange. Investors place warrant trading orders on a regular stock trading account. Securities companies are only allowed to receive orders to buy or sell warrants from investors when the investor has one hundred percent (100%) of money or warrants to transact according to relevant legal regulations. Securities companies are not allowed to allow investors to conduct margin transactions on warrants.

2. Payment activities for warrant transactions are carried out in accordance with the regulations of the Securities Depository Center.

3. After completing payment for the warrant purchase transaction, the investor becomes the owner of the warrant, and the issuing organization must be responsible for fulfilling the obligations arising from the warrants that the investor owns.

4. The organization issuing the underlying securities is not allowed to invest or trade in warrants based on that organization's securities.

5. Foreign investors are not limited in their ownership ratio of warrants.

6. Public funds can only invest in warrants for the purpose of risk prevention.”

Thus, according to regulations, an organization issuing underlying securities is not allowed to invest in or trade covered warrants based on that organization's securities.