SEC Comment Letter 0000000000-23-011999 to CHINA SOUTHERN AIRLINES CO LTD (CHKIF) (CIK 0001041668) (CHKIF)
CHINA SOUTHERN AIRLINES CO LTD (CHKIF) (CIK 0001041668)
Date: Nov. 2, 2023 · CIK: 0001041668 · Accession: 0000000000-23-011999
AI Filing Summary & Sentiment
File numbers found in text: 001-14660
Letter
United States securities and exchange commission logo November 2, 2023 Chen Weihua Chief Legal Adviser CHINA SOUTHERN AIRLINES CO LTD 68 QI XIN ROAD Guangzhou, 510403 People's Republic of China Re:CHINA SOUTHERN AIRLINES CO LTD Form 20-F for the Fiscal Year Ended December 31, 2022 File No. 001-14660 Dear Chen Weihua: We have reviewed your filing and have the following comment. 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. Form 20-F for Fiscal Year Ended December 31, 2002 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 114 1.We note your response to prior comment 2 indicates that none of the five directors you previously identified as members of the Chinese Communist Party is an official of the Chinese Communist Party because none of these five directors works in any Chinese governmental body. Please refer to your response dated August 25, 2023, and explain to us in detail how you reasonably concluded that the three directors with CCP official titles of Party Secretary or Deputy Party Secretary of CSAH are not CCP officials given their official titles, roles and responsibilities. In doing so, please describe in detail the roles and responsibilities corresponding to each official title. 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 Austin Pattan at 202-551-6756 or Jennifer Thompson at 202-551-3737 with any other questions.
FirstName LastNameChen Weihua Comapany NameCHINA SOUTHERN AIRLINES CO LTD November 2, 2023 Page 2 FirstName LastName Chen Weihua CHINA SOUTHERN AIRLINES CO LTD November 2, 2023 Page 2 Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: James Scoville
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United States securities and exchange commission logo
November 2, 2023
Chen Weihua
Chief Legal Adviser
CHINA SOUTHERN AIRLINES CO LTD
68 QI XIN ROAD
Guangzhou, 510403
People's Republic of China
Re:CHINA SOUTHERN AIRLINES CO LTD
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 001-14660
Dear Chen Weihua:
We have reviewed your filing and have the following comment.
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.
Form 20-F for Fiscal Year Ended December 31, 2002
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 114
1.We note your response to prior comment 2 indicates that none of the five directors you
previously identified as members of the Chinese Communist Party is an official of the
Chinese Communist Party because none of these five directors works in any Chinese
governmental body. Please refer to your response dated August 25, 2023, and explain to
us in detail how you reasonably concluded that the three directors with CCP official titles
of Party Secretary or Deputy Party Secretary of CSAH are not CCP officials given their
official titles, roles and responsibilities. In doing so, please describe in detail the roles and
responsibilities corresponding to each official title.
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 Austin Pattan at 202-551-6756 or Jennifer Thompson at 202-551-3737
with any other questions.
FirstName LastNameChen Weihua
Comapany NameCHINA SOUTHERN AIRLINES CO LTD
November 2, 2023 Page 2
FirstName LastName
Chen Weihua
CHINA SOUTHERN AIRLINES CO LTD
November 2, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: James Scoville