SEC Comment Letter for SUNRISE REAL ESTATE GROUP INC (SRRE) (CIK 0001083490) (SRRE) — Sep 17, 2018
SUNRISE REAL ESTATE GROUP INC (SRRE) (CIK 0001083490)
Date: Sept. 17, 2018 · CIK: 0001083490 · Accession: 0000000000-18-028786
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Letter
Mail Stop 3233 September 14, 2018 Via Email Mr. Mi Yong Jun Chief Financial Officer Sunrise Real Estate Group, Inc. No. 638, Hengfeng Road 5A11 Floor, Building A Shanghai, PRC 200070
Re: Sunrise Real Estate Group, Inc. Form 10-K Filed May 15, 2018 Form 10 -Q Filed August 14, 2018 File No. 000 -32585
Dear Mr. Mi:
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10 -K for the year ended December 31, 2017
Report of Independent Registered Public Accounting Firm, page 27
1. Please have your auditor revise their report to comply with AS 3101, The Auditor’s Report on an Audit of Financial Statements When the Audito r Expresses an Unqualified Opinion , which was effective for all audits of fiscal years ending on or after December 15, 2017 .
Mi Yong Jun Sunrise Real Estate Group, Inc. September 14, 2018 Page 2
Consolidated Statements of Cash Flows, page 32
2. We note your disclosure on page 38 that for the years ended December 31, 2017 and 2016, the Company did not recognize any impairment for real estate property under development. Please explain why you have included adjustments of $427 thousand and $288 thousand, respectively, for impairment loss on real estate property under develop ment for the years ended December 31, 2017 and 2016 on the consolidated statements of cash flows.
Form 10 -Q for the quarter ended June 30, 2018
Revenue Recognition, page 9
3. Please tell us if you adopted AS C 606, Revenue from Contracts with Customers , and if so, the impact it had on y our revenue recognition policy and consolidated financial statements. Please also provide to us, supplementally and in future filings, the disclosures required by ASC 606 -10-50.
We remind you that the company and its manage ment 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 Kristi Marrone, Staff Accountant, at (202) 551 -3429 or me at (202) 551-3629 with any questions.
Sincerely,
/s/ Kevin Woody
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Mail Stop 3233 September 14, 2018 Via Email Mr. Mi Yong Jun Chief Financial Officer Sunrise Real Estate Group, Inc. No. 638, Hengfeng Road 5A11 Floor, Building A Shanghai, PRC 200070 Re: Sunrise Real Estate Group, Inc. Form 10-K Filed May 15, 2018 Form 10 -Q Filed August 14, 2018 File No. 000 -32585 Dear Mr. Mi: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10 -K for the year ended December 31, 2017 Report of Independent Registered Public Accounting Firm, page 27 1. Please have your auditor revise their report to comply with AS 3101, The Auditor’s Report on an Audit of Financial Statements When the Audito r Expresses an Unqualified Opinion , which was effective for all audits of fiscal years ending on or after December 15, 2017 . Mi Yong Jun Sunrise Real Estate Group, Inc. September 14, 2018 Page 2 Consolidated Statements of Cash Flows, page 32 2. We note your disclosure on page 38 that for the years ended December 31, 2017 and 2016, the Company did not recognize any impairment for real estate property under development. Please explain why you have included adjustments of $427 thousand and $288 thousand, respectively, for impairment loss on real estate property under develop ment for the years ended December 31, 2017 and 2016 on the consolidated statements of cash flows. Form 10 -Q for the quarter ended June 30, 2018 Revenue Recognition, page 9 3. Please tell us if you adopted AS C 606, Revenue from Contracts with Customers , and if so, the impact it had on y our revenue recognition policy and consolidated financial statements. Please also provide to us, supplementally and in future filings, the disclosures required by ASC 606 -10-50. We remind you that the company and its manage ment 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 Kristi Marrone, Staff Accountant, at (202) 551 -3429 or me at (202) 551-3629 with any questions. Sincerely, /s/ Kevin Woody Kevin Woody Branch Chief Office of Real Estate and Commodities Cc: Bryan Lin (via email) Steven Schuster (via email)