SEC Comment Letter for CHINA PROPERTIES DEVELOPMENTS INC (CIK 0001174741) — Oct 21, 2005
CHINA PROPERTIES DEVELOPMENTS INC (CIK 0001174741)
Date: Oct. 21, 2005 · CIK: 0001174741 · Accession: 0000000000-05-053777
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Mail Stop 4561
October 21, 2005
Mr. Shawn Erickson
Chief Executive Officer
Bangla Property Management, Inc.
3540 Albert Street
Regina, Saskatchewan, Canada S4S 3P5
Re: Bangla Property Management, Inc.
Form 10-KSB for Fiscal Year Ended March 31, 2005
Filed July 7, 2005
Form 10-QSB for Fiscal Quarter Ended June 30, 2005
Filed August 18, 2005
File No. 0-50637
Dear Mr. Erickson:
We have reviewed your above referenced filings and have the
following comments. We have limited our review to only your
financial statements and related disclosures and do not intend to
expand our review to other portions of your documents. Where
indicated, we think you should revise your documents in response
to
these comments. If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation. In some
of
our comments, we may ask you to provide us with information so we
may
better understand your disclosure. After reviewing this
information,
we may raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 10-KSB for the Fiscal Year Ended March 31, 2005
Item 8A - Controls and Procedures, page 22
1. Pursuant to Item 307 of Regulation S-B, revise to disclose the
conclusions of your chief executive officer and chief financial
officer regarding the effectiveness of your disclosure controls
and
procedures as of the end of the period covered by the report.
Please
make conforming changes to the Form 10-QSB for the quarter ended
June
30, 2005.
2. Please revise to disclose changes in internal control over
financial reporting pursuant to Item 308(c) of Regulation S-B.
Please make conforming changes to the Form 10-QSB for the quarter
ended June 30, 2005.
Item 13 - Exhibits and Reports on Form 8-K, page 26
3. Please revise the certification included as exhibit 31.1 to
conform exactly to the presentation set forth in Item 601(b)(31)
of
Regulation S-B, if such statements continue to be true considering
the revised wording and evaluation date as of the period end,
rather
than as of a date within 90 days of the filing. Refer to
Management`s Report on Internal Control over Financial Reporting
and
Certification of Disclosure in Exchange Act Periodic Reports, SEC
Release No. 33-8238, available on our website at
<http://www.sec.gov/rules/final/33-8238.htm> for guidance. Please
make conforming changes to the Form 10-QSB for the quarter ended
June
30, 2005.
4. Please revise the certification included as exhibit 32.1 to
reflect the appropriate period ended date.
As appropriate, please amend your filings and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information. Detailed cover letters
greatly
facilitate our review. Please file your cover letter on EDGAR.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.
You may contact Amanda Sledge, Staff Accountant, at (202)
551-
3473 or the undersigned at (202) 551-3431 if you have questions.
Sincerely,
Josh Forgione
Staff Accountant
Mr. Shawn Erickson
Bangla Property Management, Inc.
October 21, 2005
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