SEC Comment Letter for Freedom Holding Corp. (FRHC) (CIK 0000924805) (FRHC) — Jan 12, 2016
Freedom Holding Corp. (FRHC) (CIK 0000924805)
Date: Jan. 12, 2016 · CIK: 0000924805 · Accession: 0000000000-16-061153
AI Filing Summary & Sentiment
Letter
Mail Stop 4628 January 12, 2016 Timur Turlov Chief Executive Officer BMB Munai, Inc. 324 South 400 West Suite 150 Salt Lake City, Utah 84101
Re: BMB Munai, Inc. Form 8-K Response Dated December 23, 2015 File No. 001 -33034
Dear Mr. Turlov :
We have reviewed your December 23, 2015 response to our comment letter and have the following comments. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circums tances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 17, 2015 letter .
Overview, page 5
1. We note your response to our prior comment 2. Please expand your disclosure to identify the intermediary.
Completion of Acquisition or Disposition of Assets, page 3
2. We note your proposed revised disclosure regarding the possible implications of being a “controlled company.” Please also disclose that Mr. Turlov currently has sole voting and operating control over the company.
Timur Turlov BMB Munai, Inc. January 12, 2016 Page 2
Exhibits, page 50
3. Provide us with the letter of intent and explain under what contractual arrangements Lek Securities Corpor ation will provide you with clearing services.
FFIN Securities, Inc.
Financial Statements for the Three and Six Months Ended September 30, 2015, page F -14
4. We reissue prior comment 7 as a statement of operations and a statement of cash flows for the period from August 25, 2014 (inception) – September 30, 2014 should be presented to comply with Rule 8 -03 of Regulation S -X.
You may contact Wei Lu, Staff Accountant, at (202) 551 -3725 or Ethan Horowitz, Branch Chief, at (202) 551 -3311 if you have questio ns regarding comments on the financial statements and related matters. Please contact Anuja A. Majmudar , Attorney -Advisor, at (202) 551-3844 or me at (202) 551 -3745 with any other questions.
Sincerely,
/s/H. Roger Schwall
Show Raw Text
Mail Stop 4628
January 12, 2016
Timur Turlov
Chief Executive Officer
BMB Munai, Inc.
324 South 400 West
Suite 150
Salt Lake City, Utah 84101
Re: BMB Munai, Inc.
Form 8-K
Response Dated December 23, 2015
File No. 001 -33034
Dear Mr. Turlov :
We have reviewed your December 23, 2015 response to our comment letter and have the
following comments. In some of our comments , we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circums tances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our December
17, 2015 letter .
Overview, page 5
1. We note your response to our prior comment 2. Please expand your disclosure to identify
the intermediary.
Completion of Acquisition or Disposition of Assets, page 3
2. We note your proposed revised disclosure regarding the possible implications of being a
“controlled company.” Please also disclose that Mr. Turlov currently has sole voting and
operating control over the company.
Timur Turlov
BMB Munai, Inc.
January 12, 2016
Page 2
Exhibits, page 50
3. Provide us with the letter of intent and explain under what contractual arrangements Lek
Securities Corpor ation will provide you with clearing services.
FFIN Securities, Inc.
Financial Statements for the Three and Six Months Ended September 30, 2015, page F -14
4. We reissue prior comment 7 as a statement of operations and a statement of cash flows
for the period from August 25, 2014 (inception) – September 30, 2014 should be
presented to comply with Rule 8 -03 of Regulation S -X.
You may contact Wei Lu, Staff Accountant, at (202) 551 -3725 or Ethan Horowitz,
Branch Chief, at (202) 551 -3311 if you have questio ns regarding comments on the financial
statements and related matters. Please contact Anuja A. Majmudar , Attorney -Advisor, at (202)
551-3844 or me at (202) 551 -3745 with any other questions.
Sincerely,
/s/H. Roger Schwall
H. Roger Schwall
Assistant Director
Offic ial of Natural Resources