This deal must have taken a lot of time to put together since we got the 2.5 million last year. That means CRRC has had many months to buy shares between .25 and .40 knowing that they would be able to convert the loan later.
If I was running CRRC I would have been buying lots of shares but not enough to triger any disclousure. I would then be selling those shares for a nice profit knowing I can replace the shares for .40.
If the disclosure was at say 15 million shares they could have made say .30 a share. That is about 4.5 million. I don't know if true but I would do it.