SEC Comment Letter for Freedom Holding Corp. (FRHC) (CIK 0000924805) (FRHC) — Mar 29, 2006
Freedom Holding Corp. (FRHC) (CIK 0000924805)
Date: March 29, 2006 · CIK: 0000924805 · Accession: 0000000000-06-014987
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-0405 DIVISION OF CORPORATION FINANCE Mail Stop 7010 March 29, 2006 Mr. Sanat Kasymov Chief Financial Officer BMB Munai, Inc. % Poulton & Yordan 324 South 400 West, Suite 250 Salt Lake City, Utah 84101
Re: BMB Munai, Inc. Item 4.02 Form 8-K Filed March 28, 2006 File No. 0-28638
Dear Mr. Kasymov:
We have reviewed your filing and have the follo wing comments. Where indicated, we think you should revise your document in response to these comm ents. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnece ssary. 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 information, we may raise additional comments.
Please understand that the purpose of our review process is to a ssist 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 th e telephone numbers listed at the end of this letter.
1. We note that you intend to file restated financial statements. However you have not indicated how or when you intend to do so. Please tell us how and when you intend to file restat ed financial statements. We may have further comment after you f ile the restated financial statements.
2. Please tell us if your certifying officers have reconsidered the effect on the adequacy of your disclosure controls and procedures as of the end of the period c overed by your Form 10-KSB for the period ended March 31, 2005 and Forms 10-QSB for the periods ended June 30, September 30, and December 31, 2005 in light of the material error you ha ve disclosed. Additionally, tell us what effect the error had on your current evaluation of disclosure controls and procedures as of your fiscal year end March 31, 2006.
Mr. Sanat Kasymov BMB Munai, Inc. March 29, 2006 page 2
As appropriate, please amend your filing and re spond to these comments within five business days or tell us when you will provide us with a response. 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 a ny requested information. Detailed cover letters greatly facilitate our review. Pl ease understand that we may have a dditional comments after reviewing your amendment and responses to our comments.
We urge all persons who are responsible for th e 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 possessi on of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequa cy 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 disclo sure in the filing;
staff comments or changes to disclosure in re sponse 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 Enfo rcement 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 Gary Ne wberry at (202) 551-3761, or me at (202) 551-3684.
S i n c e r e l y ,
A p r i l S i f f o r d B r a n c h C h i e f
cc: Mr. Richard T. Ludlow, Attorney at Law
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405
DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
March 29, 2006
Mr. Sanat Kasymov
Chief Financial Officer
BMB Munai, Inc.
% Poulton & Yordan
324 South 400 West, Suite 250
Salt Lake City, Utah 84101
Re: BMB Munai, Inc.
Item 4.02 Form 8-K
Filed March 28, 2006
File No. 0-28638
Dear Mr. Kasymov:
We have reviewed your filing and have the follo wing comments. Where indicated, we think you
should revise your document in response to these comm ents. If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is unnece ssary. 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 information, we may raise
additional comments.
Please understand that the purpose of our review process is to a ssist 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 th e telephone numbers listed at the end
of this letter.
1. We note that you intend to file restated financial statements. However you have not indicated how or
when you intend to do so. Please tell us how and when you intend to file restat ed financial statements.
We may have further comment after you f ile the restated financial statements.
2. Please tell us if your certifying officers have reconsidered the effect on the adequacy of your
disclosure controls and procedures as of the end of the period c overed by your Form 10-KSB for the
period ended March 31, 2005 and Forms 10-QSB for the periods ended June 30, September 30, and
December 31, 2005 in light of the material error you ha ve disclosed. Additionally, tell us what effect
the error had on your current evaluation of disclosure controls and procedures as of your fiscal year
end March 31, 2006.
Mr. Sanat Kasymov
BMB Munai, Inc.
March 29, 2006
page 2
As appropriate, please amend your filing and re spond to these comments within five business
days or tell us when you will provide us with a response. 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 a ny requested information. Detailed cover letters
greatly facilitate our review. Pl ease understand that we may have a dditional comments after reviewing
your amendment and responses to our comments.
We urge all persons who are responsible for th e 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 possessi on of all facts relating to a company’s disclosure,
they are responsible for the accuracy and adequa cy 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 disclo sure in the filing;
staff comments or changes to disclosure in re sponse 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 Enfo rcement 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 Gary Ne wberry at (202) 551-3761, or me at (202) 551-3684.
S i n c e r e l y ,
A p r i l S i f f o r d
B r a n c h C h i e f
cc: Mr. Richard T. Ludlow, Attorney at Law