SEC Comment Letter for FIRST CAPITAL INTERNATIONAL INC (CIK 0001072842) — Dec 10, 2021
FIRST CAPITAL INTERNATIONAL INC (CIK 0001072842)
Date: Dec. 10, 2021 · CIK: 0001072842 · Accession: 0000000000-21-014870
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File numbers found in text: 000-26271
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United States securities and exchange commission logo
December 10, 2021
Alex Genin
President
First Capital International, Inc.
5829 W Sam Houston Pkwy N, Suite 405
Houston, Texas 77041
Re:First Capital International, Inc.
Amendment No. 1 to Registration Statement on Form 10-12G
Filed November 29, 2021
File No. 000-26271
Dear Mr. Genin:
We have reviewed your filing and have the following comment.
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 and any amendment you may file in response to
this comment, we may have additional comments.
Amendment No. 1 to Registration Statement on Form 10-12G
Item 13. Financial Statements and Supplementary Data, page 22
1.As you prepare your amended document, please be aware of the requirements set forth in
Rule 8-08 of Regulation S-X regarding the age of the financial statements included in
your filing. Please update your financial statements as needed to ensure the requirements
are met as of the anticipated date of automatic effectiveness of the registration statement.
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.
You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Olivia Bobes, Law
Clerk, at (202) 551-7361 or Mitchell Austin, Staff Attorney, at (202) 551-3574 with any other
questions.
FirstName LastNameAlex Genin
Comapany NameFirst Capital International, Inc.
December 10, 2021 Page 2
FirstName LastName
Alex Genin
First Capital International, Inc.
December 10, 2021
Page 2
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Robert Axelrod, Esq.