SEC Comment Letter 0000000000-23-010157 to PETROCHINA CO LTD (PCCYF) (CIK 0001108329) (PCCYF)
PETROCHINA CO LTD (PCCYF) (CIK 0001108329)
Date: Sept. 14, 2023 · CIK: 0001108329 · Accession: 0000000000-23-010157
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File numbers found in text: 001-15006
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United States securities and exchange commission logo
September 14, 2023
Wang Hua
Chief Financial Officer
PetroChina Company Limited
9 Dongzhimen North Street
Dongcheng District, Beijing 100007
The People's Republic of China
Re:PetroChina Company Limited
Form 20-F for the Fiscal Year Ended December 31, 2022
Response dated September 8, 2023
File No. 001-15006
Dear Wang Hua:
We have reviewed your September 8, 2023 response to our comment letter 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 business days by providing the requested
information or advise 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. Unless we note otherwise, our references to prior comments are to comments in our
August 4, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 122
1.We note your response to prior comment 2 that Item 16I(b) of Form 20-F states: “any
such identified foreign issuer that uses a variable-interest entity or any similar structure
that results in additional foreign entities being consolidated in the financial statements of
the registrant is required to provide the below disclosures for itself and its consolidated
foreign operating entity or entities.” In that regard, page 15 of our SEC Release No. 34-
93701, “Holding Foreign Companies Accountable Act Disclosure,” clarifies that a
registrant should “look through a VIE or any structure that results in additional foreign
entities being consolidated in the financial statements of the registrant and provide the
required disclosures about any consolidated operating company or companies in the
FirstName LastNameWang Hua
Comapany NamePetroChina Company Limited
September 14, 2023 Page 2
FirstName LastName
Wang Hua
PetroChina Company Limited
September 14, 2023
Page 2
relevant jurisdiction.” Per pages F-50 and F-51 of the 20-F, you have subsidiaries outside
of China. As previously requested, please provide us with the information required by
Items 16I(b)(2) through (b)(5) for all of your consolidated foreign operating entities.
2.We note your response to prior comment 3 and re-issue. Please confirm, if true, that your
reference to “CPC members” includes officials of the Chinese Communist Party as
required by Item 16I(b)(4) of Form 20-F.
3.We note your response to prior comment 4 and re-issue. Please supplementally describe
the steps you have taken to confirm that completeness of the disclosure regarding the
names of members of the boards of your consolidated foreign operating entities who are
officials of the Chinese Communist Party.
Please contact Jimmy McNamara at 202-551-7349 or Andrew Mew at 202-551-3377
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Kyungwon Lee