SEC Comment Letter for Freedom Holding Corp. (FRHC) (CIK 0000924805) (FRHC) — Feb 9, 2016
Freedom Holding Corp. (FRHC) (CIK 0000924805)
Date: Feb. 9, 2016 · CIK: 0000924805 · Accession: 0000000000-16-064295
AI Filing Summary & Sentiment
Letter
Mail Stop 4628 February 9 , 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 January 20, 2016 File No. 001 -33034
Dear Mr. Turlov :
We have reviewed your January 20, 2016 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 January 12, 2016 letter .
Overview, page 5
1. We note your response to our prior comment 1. In light of the fact that you only have a letter of intent in place with Lek Securities Corporation, please ensure that your revised disclosure in this section does not imply that FFINRU Investments Limited i s currently engaging Lek Securities Corporation to execute orders in the U.S. In this regard we note that you propose to state “FFINRU introduces these customers to Lek Securities Corporation…a licensed U.S. clearing broker -dealer and FINRA member that ex ecutes the customers’ orders and clears the transactions.”
You may contact Wei Lu, Staff Accountant, at (202) 551 -3725 or Ethan Horowitz, Branch Chief, at (202) 551 -3311 if you have questions regarding comments on the financial
Timur Turlov BMB Munai, Inc. February 9, 2016 Page 2
statements and related ma tters. 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
February 9 , 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 January 20, 2016
File No. 001 -33034
Dear Mr. Turlov :
We have reviewed your January 20, 2016 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 January 12,
2016 letter .
Overview, page 5
1. We note your response to our prior comment 1. In light of the fact that you only have a
letter of intent in place with Lek Securities Corporation, please ensure that your revised
disclosure in this section does not imply that FFINRU Investments Limited i s currently
engaging Lek Securities Corporation to execute orders in the U.S. In this regard we note
that you propose to state “FFINRU introduces these customers to Lek Securities
Corporation…a licensed U.S. clearing broker -dealer and FINRA member that ex ecutes
the customers’ orders and clears the transactions.”
You may contact Wei Lu, Staff Accountant, at (202) 551 -3725 or Ethan Horowitz,
Branch Chief, at (202) 551 -3311 if you have questions regarding comments on the financial
Timur Turlov
BMB Munai, Inc.
February 9, 2016
Page 2
statements and related ma tters. 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
Official of Natural Resources