Contrarian Corpus
short seller research note initial thesis
2012-07-18 · 97 pages

New Oriental Education & Technology Group EDU

New Oriental is hiding an extensive franchising operation, filing fraudulent tax-exempt financials in Beijing and using a cosmetic VIE — expect a restatement and Deloitte to resign.

N 5 Narrative
V 2 Visual
C 2 Craft
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Thesis

Muddy Waters rates New Oriental Education (NYSE: EDU, $14.62, $2.3bn market cap) a Strong Sell, arguing the company's reported 392% revenue growth and 338% store growth since its 2006 IPO are built on an undisclosed franchise network that CFO Louis Hsieh has repeatedly and explicitly denied — Muddy Waters produces a subtitled recording of an EDU representative describing fees of RMB 600k–1MM per city. EDU almost certainly consolidates franchisees' results and uses upfront fees to game Deloitte's cash-balance confirmations. Its Beijing operation, ~35% of revenue, claims a 0% enterprise-income-tax exemption that is legally impossible, rendering those financials fraudulent and likely contaminating EDU's SEC filings. A cosmetic equity pledge, missing proxy agreement and schools that by PRC law belong to the state leave shareholders exposed. A restatement and auditor resignation are probable.

SCQA

Situation

New Oriental (NYSE: EDU) is a $2.3bn, Deloitte-audited Chinese for-profit education company reporting 392% revenue growth, 338% store growth and 60%+ gross margins since its 2006 IPO, with Beijing contributing ~35% of revenue.

Complication

CFO Louis Hsieh publicly denies any franchising while EDU runs an undisclosed franchise network across dozens of cities, consolidates franchisees' results and upfront fees as its own, and files fraudulent 0%-tax financials for its Beijing operation.

Resolution

Sell EDU. Muddy Waters argues investors should treat reported numbers as unreliable, expect a significant restatement of historical results, anticipate Deloitte's resignation and challenge the legitimacy of EDU's VIE-consolidated schools.

Reward

Muddy Waters declines to set a price target — 'we cannot reliably value EDU without more information' — but investors avoid losses from the probable restatement, auditor resignation and further SEC scrutiny now that the SEC has opened an investigation.

The three reasons

  1. 1

    CFO Louis Hsieh denies franchising on tape while EDU runs an undisclosed franchise network

  2. 2

    Beijing operation (~35% of revenue) claims an impossible 0% tax exemption — financials are fraudulent

  3. 3

    Weak VIE leaves operating schools with Chairman Yu; by PRC law they ultimately belong to the state

Primary demands

  • Sell EDU (Strong Sell)
  • Demand EDU disclose the full scope of its franchising operation
  • Scrutinize Deloitte's audit and expect auditor resignation
  • Require restatement of historical financials including Beijing operation
  • Reject EDU's VIE structure as providing insufficient shareholder protection

KPIs cited

Revenue growth since IPO
392% since Sept 2006, a 37.0% FY2006-FY2011 CAGR
Store count growth since IPO
338% growth, 29.1% CAGR FY2006-FY2011
Reported gross margin FY2011
60.1% — but MW says Tier 1 caps at ~30%, Tier 2-3 at ~20%
Beijing operation revenue CY2011
$207.7MM, ~35% of consolidated revenue; claims 0% EIT exemption
FY2011 audit fee vs FY2007
31.9% lower despite 195% more stores; lowest in peer group
Franchise fees per city
RMB 600,000–1,000,000 trademark fee over 3 years + RMB 80,000/year technical fee + RMB 100,000 security deposit
Capex since IPO
~$104MM reported — questioned because franchisees fund their own capex
Net cash balance CAGR
56.8% — inflated via upfront franchise fees
U.S.-listed China auditor resignations
67 per NYT; another 126 delisted or gone dark

Pattern membership

Where this document fits across the library's 12 rhetorical / structural patterns.

Precedents cited

  • OLP Global's November 2011 EDU fraud report
  • Peregrine Financial Group (forged cash balances)
  • China MediaExpress (sham dividend to validate numbers)
  • Longtop Financial Technologies (China fraud blow-up)
  • Baidu (BIDU) VIE package as best-practice comparison
  • Enron / FIN 46 origin of the VIE consolidation loophole

Notable slides (6)

Notes

Classic Muddy Waters short: 'Magna Cum Fraude' title, a long-form Word-style memo (not a slide deck) with embedded screenshots, a translated franchise-application flowchart, a peer customer-service bar chart and gross/operating margin tables. Rhetorical centerpiece is a verbatim Q&A transcript of CFO Louis Hsieh denying any franchisees, juxtaposed with a subtitled recorded call of an EDU employee pitching a franchise (RMB 600k–1MM per city). Also notable: an analytics screenshot of an apparent DoS attack on MW's server and Gmail 'state-sponsored attacker' warnings framed as evidence of CPC hostility. No explicit price target — MW declines to value. Stake not disclosed (short position generically disclaimed). Cover states 'Director of Research: Carson C. Block, Esq.'; Block is credited as author. SEC investigation of EDU was announced July 17, 2012, one day before this report.