SEC Comment Letter 0000000000-23-011807 to CHINA PHARMA HOLDINGS, INC. (CPHI) (CIK 0001106644) (CPHI)
CHINA PHARMA HOLDINGS, INC. (CPHI) (CIK 0001106644)
Date: Oct. 27, 2023 · CIK: 0001106644 · Accession: 0000000000-23-011807
AI Filing Summary & Sentiment
File numbers found in text: 001-34471
Letter
United States securities and exchange commission logo October 27, 2023 Zhilin Li Interim Chief Financial Officer China Pharma Holdings, Inc. Second Floor, No. 17, Jinpan Road Haikou, Hainan Province, China, 570216 Re:China Pharma Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Filed March 30, 2023 Response dated October 18, 2023 File No. 001-34471 Dear Zhilin Li: We have reviewed your response 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 10-K for Fiscal Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 1.We have read your response to prior comment 2. As previously requested, please revise to disclose the extent to which there are explicit contractual provisions regarding the payment of account receivables to you which are contingent on the receipt of payments from state-owned hospitals and local medicine distributors and and to disclose the level of your insight on the receipt of payments by your customer distributors from their state- owned hospitals as indicated in your response. Provide us with a draft of your proposed disclosure. 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.
FirstName LastNameZhilin Li Comapany NameChina Pharma Holdings, Inc. October 27, 2023 Page 2 FirstName LastName Zhilin Li China Pharma Holdings, Inc. October 27, 2023 Page 2 Please contact Tracie Mariner at 202-551-3744 or Kevin Vaughn at 202-551-3494 if you have questions regarding comments on the financial statements and related matters. Please contact Dillon Hagius at 202-551-7967 or Jason Drory at 202-551-8342 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
October 27, 2023
Zhilin Li
Interim Chief Financial Officer
China Pharma Holdings, Inc.
Second Floor, No. 17, Jinpan Road
Haikou, Hainan Province, China, 570216
Re:China Pharma Holdings, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed March 30, 2023
Response dated October 18, 2023
File No. 001-34471
Dear Zhilin Li:
We have reviewed your response 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 10-K for Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
46
1.We have read your response to prior comment 2. As previously requested, please revise to
disclose the extent to which there are explicit contractual provisions regarding the
payment of account receivables to you which are contingent on the receipt of payments
from state-owned hospitals and local medicine distributors and and to disclose the level of
your insight on the receipt of payments by your customer distributors from their state-
owned hospitals as indicated in your response. Provide us with a draft of your proposed
disclosure.
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.
FirstName LastNameZhilin Li
Comapany NameChina Pharma Holdings, Inc.
October 27, 2023 Page 2
FirstName LastName
Zhilin Li
China Pharma Holdings, Inc.
October 27, 2023
Page 2
Please contact Tracie Mariner at 202-551-3744 or Kevin Vaughn at 202-551-3494 if you
have questions regarding comments on the financial statements and related matters. Please
contact Dillon Hagius at 202-551-7967 or Jason Drory at 202-551-8342 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences