Correspondence 0001493152-24-039545 from SELECTIS HEALTH, INC. (GBCS)
SELECTIS HEALTH, INC.
Date: Oct. 4, 2024 · CIK: 0000727346 · Accession: 0001493152-24-039545
AI Filing Summary & Sentiment
File numbers found in text: 000-15415
Letter
E. Orchard Rd, Ste 4900
Greenwood Village, CO 80111
Via Edgar Filing
October 4, 2024
Kellie Kim
Division of Corporation Finance
US Securities and Exchange Commission
Washington, DC
Re: Selectis Health, Inc.
Form 10-K for the year ended December 31,2023
Filed April 16, 2024
File No. 000-15415
Ladies and Gentlemen:
Please accept the following in response to the comments of the Commission dated August 8, 2024.
Form 10-K for the year ended December 31,2023
Item 9A. Controls and Procedures
Management’s Annual Report on Internal Control over Financial Reporting, page 24
1. We note that based on your evaluation, management concluded that disclosure controls and procedures were not effective as of December 31, 2023 due to material weaknesses in internal controls over financial reporting. Please revise to explicitly state management’s conclusion regarding internal control over financial reporting as of December 31, 2023.
Response: Revised as requested, see Item 9A, page 24 of Amendment No. 1
Exhibits
2. We note that Exhibits 32.1 and 32.2 refer to the Annual Report of Selectis Health, Inc. (the “Company”) on Form 10-K for the period ended December 31, 2022. Please file a full amendment to furnish Section 902 certifications that refer to the Form 10-K for the period ended December 31, 2023.
Response: Revised as requested, see revised exhibits
General
3. We note the sale of the Archway Property effective June 18, 2024. Please confirm that in future periodic filings you will provide robust MD&A disclosure of this sale and the anticipated impact on your operating revenues and expenses to the extent material.
Response: Confirmed as requested.
October 4, 2024
Page
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Sincerely,
/s/
James Creamer, III
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filename1.htm
8480
E. Orchard Rd, Ste 4900
Greenwood
Village, CO 80111
Via
Edgar Filing
October
4, 2024
Kellie
Kim
Division
of Corporation Finance
US
Securities and Exchange Commission
Washington,
DC
Re:
Selectis
Health, Inc.
Form
10-K for the year ended December 31,2023
Filed
April 16, 2024
File
No. 000-15415
Ladies
and Gentlemen:
Please
accept the following in response to the comments of the Commission dated August 8, 2024.
Form
10-K for the year ended December 31,2023
Item 9A. Controls and Procedures
Management’s
Annual Report on Internal Control over Financial Reporting, page 24
1. We
note that based on your evaluation, management concluded that disclosure controls and procedures
were not effective as of December 31, 2023 due to material weaknesses in internal controls
over financial reporting. Please revise to explicitly state management’s conclusion
regarding internal control over financial reporting as of December 31, 2023.
Response:
Revised as requested, see Item 9A, page 24 of Amendment No. 1
Exhibits
2. We
note that Exhibits 32.1 and 32.2 refer to the Annual Report of Selectis Health, Inc. (the
“Company”) on Form 10-K for the period ended December 31, 2022. Please file a
full amendment to furnish Section 902 certifications that refer to the Form 10-K for the
period ended December 31, 2023.
Response:
Revised as requested, see revised exhibits
General
3. We
note the sale of the Archway Property effective June 18, 2024. Please confirm that in future
periodic filings you will provide robust MD&A disclosure of this sale and the anticipated
impact on your operating revenues and expenses to the extent material.
Response:
Confirmed as requested.
October
4, 2024
Page
2
We
remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any
review, comments, action or absence of action by the staff.
Sincerely,
/s/
James Creamer, III
James
Creamer, III
Chief
Financial Officer
Selectis
Health, Inc.