SEC Comment Letter for SELECTIS HEALTH, INC. (GBCS) (CIK 0000727346) (GBCS) — Oct 31, 2013
SELECTIS HEALTH, INC. (GBCS) (CIK 0000727346)
Date: Oct. 31, 2013 · CIK: 0000727346 · Accession: 0000000000-13-059832
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE October 30, 2013 Via e -mail Mr. Christopher Brogdon President Global Healthcare REIT, Inc. 3050 Peachtree Road NW, Suite 355 Atlanta, GA 30305
Re: Global Healthcare REIT, Inc. Item 4.01 Form 8 -K Filed October 25, 2013 File No. 0-15415
Dear Mr. Brogdon :
We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with more information so we may better understand your disclosure. After reviewing this i nformation, we may raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
General 1. Your disclosure indicates that Sc humacher & Associates, Inc. informed you of their resignation effective October 21, 2013. However, you then identify October 18, 2013 as the date of resignation. Please file an amendment to your Form 8 -K to reconcile these dates. 2. Related to the comment a bove, please ensure that your disclosure concerning disagreements and/or reportable events is through the effective date of resignation.
Mr. Christopher Brogdon Global Healthcare REIT, Inc. October 30, 2013 Page 2
Exhibit 16 3. To the extent that you make changes to the Form 8 -K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in your revised Form 8 -K.
As appropriate, please amend your filing and respond to these comments within five business days or tell us when you will respond. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
If you have any questions, please call me at (202) 551 -3432 .
Sincerely,
/s/ William H. Demarest, IV
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
October 30, 2013
Via e -mail
Mr. Christopher Brogdon
President
Global Healthcare REIT, Inc.
3050 Peachtree Road NW, Suite 355
Atlanta, GA 30305
Re: Global Healthcare REIT, Inc.
Item 4.01 Form 8 -K
Filed October 25, 2013
File No. 0-15415
Dear Mr. Brogdon :
We have reviewed your filing and have the following comments. Where indicated, we
think you should revise your document in response to these comments. If you disagree, we will
consider your explanation as to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation. In some of our comments, we may ask
you to provide us with more information so we may better understand your disclosure. After
reviewing this i nformation, we may raise additional comments.
Please understand that the purpose of our review process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in
your filing. We look forward to working with you in these respects. We welcome any questions
you may have about our comments or any other aspect of our review. Feel free to call us at the
telephone numbers listed at the end of this letter.
General
1. Your disclosure indicates that Sc humacher & Associates, Inc. informed you of their
resignation effective October 21, 2013. However, you then identify October 18, 2013 as
the date of resignation. Please file an amendment to your Form 8 -K to reconcile these
dates.
2. Related to the comment a bove, please ensure that your disclosure concerning
disagreements and/or reportable events is through the effective date of resignation.
Mr. Christopher Brogdon
Global Healthcare REIT, Inc.
October 30, 2013
Page 2
Exhibit 16
3. To the extent that you make changes to the Form 8 -K to comply with our comments,
please obtain and file an updated Exhibit 16 letter from the former accountants stating
whether the accountant agrees with the statements made in your revised Form 8 -K.
As appropriate, please amend your filing and respond to these comments within five
business days or tell us when you will respond. You may wish to provide us with marked copies
of the amendment to expedite our review. Please furnish a cover letter with your amendment
that keys your responses to our comments and provides any requested information. Detailed
cover letters greatly facilitate our review. Please understand that we may have additional
comments after reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information investors require for an
informed investment decision. Since the company and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of
the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement
from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the
Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Division of Corporation Finance in our review of your
filing or in response to our comments on your filing.
If you have any questions, please call me at (202) 551 -3432 .
Sincerely,
/s/ William H. Demarest, IV
William H. Demarest, IV
Accountant
Mr. Christopher Brogdon
Global Healthcare REIT, Inc.
October 30, 2013
Page 3