SEC Comment Letter 0000000000-24-009583 to Wilhelmina International, Inc. (WHLM) (CIK 0001013706) (WHLM)
Wilhelmina International, Inc. (WHLM) (CIK 0001013706)
Date: Aug. 21, 2024 · CIK: 0001013706 · Accession: 0000000000-24-009583
AI Filing Summary & Sentiment
File numbers found in text: 001-36589
Letter
August 21, 2024 Gaurav Pahwa Chief Financial Officer Wilhelmina International, Inc. 5420 Lyndon B Johnson Freeway, Box #25 Dallas, TX 75240 Re:Wilhelmina International, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-36589 Dear Gaurav Pahwa: We have reviewed your filing and have the following comments. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Annual Report on Form 10-K for fiscal year ended December 31, 2023 Item 1C. Cybersecurity, page 8 We note the following statements on page 8: •“We have not currently engaged any third party service providers to support, manage, or supplement our cybersecurity processes.” •“The Audit Committee periodically receives updates from management and our third party IT support specialists of our cybersecurity threat risk management and mitigation strategies covering topics such as data security and potentially material cybersecurity threat risks or incidents, as well as the steps management has taken to respond to such risks.“ •“In such sessions, the Audit Committee …discusses such matters with our third party IT support specialists and other members of senior management.” These statements appear inconsistent. Please revise future filings to clarify whether you engage assessors, consultants, auditors or other third parties in connection with your processes for assessing, identifying and managing material risks from cybersecurity threats as required by Item 106(b)(1)(ii) of Regulation S-K. 1.
August 21, 2024 Page 2
2.We note your senior leadership is responsible for the day-to-day management of cybersecurity risk and the design and implementation of policies, processes and procedures to identify and mitigate this risk. Please revise future filings to discuss the relevant expertise of such members of senior management as required by Item 106(c)(2)(i) of Regulation S-K. 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. Please contact Pearlyne Paulemon at 202-551-8714 or Suzanne Hayes at 202-551-3675 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc:Quentin Faust
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August 21, 2024
Gaurav Pahwa
Chief Financial Officer
Wilhelmina International, Inc.
5420 Lyndon B Johnson Freeway, Box #25
Dallas, TX 75240
Re:Wilhelmina International, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-36589
Dear Gaurav Pahwa:
We have reviewed your filing and have the following comments.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Annual Report on Form 10-K for fiscal year ended December 31, 2023
Item 1C. Cybersecurity, page 8
We note the following statements on page 8:
•“We have not currently engaged any third party service providers to support, manage,
or supplement our cybersecurity processes.”
•“The Audit Committee periodically receives updates from management and our third
party IT support specialists of our cybersecurity threat risk management and
mitigation strategies covering topics such as data security and potentially material
cybersecurity threat risks or incidents, as well as the steps management has taken to
respond to such risks.“
•“In such sessions, the Audit Committee …discusses such matters with our third party
IT support specialists and other members of senior management.”
These statements appear inconsistent. Please revise future filings to clarify whether you
engage assessors, consultants, auditors or other third parties in connection with your
processes for assessing, identifying and managing material risks from cybersecurity
threats as required by Item 106(b)(1)(ii) of Regulation S-K.
1.
August 21, 2024
Page 2
2.We note your senior leadership is responsible for the day-to-day management of
cybersecurity risk and the design and implementation of policies, processes and
procedures to identify and mitigate this risk. Please revise future filings to discuss the
relevant expertise of such members of senior management as required by Item
106(c)(2)(i) of Regulation S-K.
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.
Please contact Pearlyne Paulemon at 202-551-8714 or Suzanne Hayes at 202-551-3675
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Quentin Faust