SEC Comment Letter for ELTEK LTD (ELTK) (CIK 0001024672) (ELTK) — May 19, 2020
ELTEK LTD (ELTK) (CIK 0001024672)
Date: May 19, 2020 · CIK: 0001024672 · Accession: 0000000000-20-004463
AI Filing Summary & Sentiment
File numbers found in text: 000-28884
Letter
United States securities and exchange commission logo May 19, 2020 Alon Mualem Chief Financial Officer ELTEK LTD 20 Ben Zion Gelis Street Sgoola Industrial Zone Petach Tikva 4927920, Israel Re:ELTEK LTD Form 20-F For the Year Ended December 31, 2019 Filed April 27, 2020 File No. 000-28884 Dear Mr. Mualem: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 20-F For the Year Ended December 31, 2019 Item 15. Controls and Procedures, page 73 1.The evaluation of your disclosure controls and procedures and internal control over financial reporting should be as of the end of the period covered by the report. In this regard, we noted that you have assessed and concluded on the effectiveness of your internal control over financial reporting as of December 31, 2018. We also note that you do not identify the version of the COSO framework you used to evaluate the effectiveness of your internal control over financial reporting. Please amend your Form 20-F to comply with the requirements of Item 308 of Regulation S-X. You may provide an abbreviated amendment that includes a cover page, explanatory note, the complete text of Item 15, a signature page and the required officer certifications.
In closing, we remind you that the company and its management are responsible for the
FirstName LastNameAlon Mualem Comapany NameELTEK LTD May 19, 2020 Page 2 FirstName LastName Alon Mualem ELTEK LTD May 19, 2020 Page 2 accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact SiSi Cheng at 202-551-5004 or John Cash at 202-551-3768 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
May 19, 2020
Alon Mualem
Chief Financial Officer
ELTEK LTD
20 Ben Zion Gelis Street
Sgoola Industrial Zone
Petach Tikva 4927920, Israel
Re:ELTEK LTD
Form 20-F For the Year Ended December 31, 2019
Filed April 27, 2020
File No. 000-28884
Dear Mr. Mualem:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 20-F For the Year Ended December 31, 2019
Item 15. Controls and Procedures, page 73
1.The evaluation of your disclosure controls and procedures and internal control over
financial reporting should be as of the end of the period covered by the report. In this
regard, we noted that you have assessed and concluded on the effectiveness of your
internal control over financial reporting as of December 31, 2018. We also note that you
do not identify the version of the COSO framework you used to evaluate the effectiveness
of your internal control over financial reporting. Please amend your Form 20-F to comply
with the requirements of Item 308 of Regulation S-X. You may provide an abbreviated
amendment that includes a cover page, explanatory note, the complete text of Item 15, a
signature page and the required officer certifications.
In closing, we remind you that the company and its management are responsible for the
FirstName LastNameAlon Mualem
Comapany NameELTEK LTD
May 19, 2020 Page 2
FirstName LastName
Alon Mualem
ELTEK LTD
May 19, 2020
Page 2
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact SiSi Cheng at 202-551-5004 or John Cash at 202-551-3768 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing