SEC Comment Letter 0000000000-23-012116 to FORMULA SYSTEMS (1985) LTD (FORTY) (CIK 0001045986) (FORTY)
FORMULA SYSTEMS (1985) LTD (FORTY) (CIK 0001045986)
Date: Nov. 6, 2023 · CIK: 0001045986 · Accession: 0000000000-23-012116
AI Filing Summary & Sentiment
File numbers found in text: 000-29442
Letter
United States securities and exchange commission logo November 6, 2023 Asaf Berenstin Chief Financial Officer Formula Systems (1985) Ltd. Yahadut Canada 1 Street Or Yehuda 6037501, Israel Re:Formula Systems (1985) Ltd. Form 20-F for the Fiscal Year Ended December 31, 2022 File No. 000-29442 Dear Asaf Berenstin: 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. Form 20-F for the Fiscal Year Ended December 31, 2022 Report of Independent Registered Accounting Firms, page F-5 1.We note that Kost, Forer, Gabbay & Kasierer's attestation report on internal control over financial reporting refers to the work of other auditors as it relates Magic Software Japan K.K, a wholly owned subsidiary of Magic Software Enterprises Ltd. Please amend your December 31, 2022 Form 20-F to include KDA Audit Corporation's opinion on Magic Software Japan K.K's Internal Control over Financial Reporting. Refer to Rule 2-05 of Regulation S-X. Note 2. Significant Accounting Policies 13) Revenue Recognition, page F-29 2.Please revise to disclose the aggregate amount of transaction prices allocated to performance obligations that are unsatisfied as of the end of the reporting period and an explanation of when you expect to recognize such revenue using time bands that would be most appropriate for the duration of the remaining performance obligation or by using qualitative information. Refer to IFRS 15.120. We refer also to your response to comment 4 in your December 9, 2020 letter.
FirstName LastNameAsaf Berenstin Comapany NameFormula Systems (1985) Ltd. November 6, 2023 Page 2 FirstName LastName Asaf Berenstin Formula Systems (1985) Ltd. November 6, 2023 Page 2 20) Impairment of Non-financial Assets, page F-39 3.We note that the recoverable amount used in assessing goodwill for impairment is the higher of the fair value less cost of sale and value in use. Please revise to include the disclosures required by paragraphs 134(d) through (f) and 135 of IAS 36, as applicable. 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 Megan Akst at 202-551-3407 or Kathleen Collins at 202-551-3499 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology cc: Guy Bernstein
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United States securities and exchange commission logo
November 6, 2023
Asaf Berenstin
Chief Financial Officer
Formula Systems (1985) Ltd.
Yahadut Canada 1 Street
Or Yehuda 6037501, Israel
Re:Formula Systems (1985) Ltd.
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 000-29442
Dear Asaf Berenstin:
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.
Form 20-F for the Fiscal Year Ended December 31, 2022
Report of Independent Registered Accounting Firms, page F-5
1.We note that Kost, Forer, Gabbay & Kasierer's attestation report on internal control over
financial reporting refers to the work of other auditors as it relates Magic Software Japan
K.K, a wholly owned subsidiary of Magic Software Enterprises Ltd. Please amend your
December 31, 2022 Form 20-F to include KDA Audit Corporation's opinion on Magic
Software Japan K.K's Internal Control over Financial Reporting. Refer to Rule 2-05 of
Regulation S-X.
Note 2. Significant Accounting Policies
13) Revenue Recognition, page F-29
2.Please revise to disclose the aggregate amount of transaction prices allocated to
performance obligations that are unsatisfied as of the end of the reporting period and an
explanation of when you expect to recognize such revenue using time bands that would be
most appropriate for the duration of the remaining performance obligation or by using
qualitative information. Refer to IFRS 15.120. We refer also to your response to comment
4 in your December 9, 2020 letter.
FirstName LastNameAsaf Berenstin
Comapany NameFormula Systems (1985) Ltd.
November 6, 2023 Page 2
FirstName LastName
Asaf Berenstin
Formula Systems (1985) Ltd.
November 6, 2023
Page 2
20) Impairment of Non-financial Assets, page F-39
3.We note that the recoverable amount used in assessing goodwill for impairment is the
higher of the fair value less cost of sale and value in use. Please revise to include the
disclosures required by paragraphs 134(d) through (f) and 135 of IAS 36, as applicable.
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 Megan Akst at 202-551-3407 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Guy Bernstein