Correspondence 0001683168-24-000178 from Strata Power Corp (SPOWF) (CIK 0001227282) (SPOWF)
Strata Power Corp (SPOWF) (CIK 0001227282)
Date: Jan. 10, 2024 · CIK: 0001227282 · Accession: 0001683168-24-000178
AI Filing Summary & Sentiment
File numbers found in text: 000-50934
Referenced dates: December 20, 2023
Show Raw Text
CORRESP
1
filename1.htm
William
E. Cooper
Attorney
at Law
10030
Conway Rd.,
St.
Louis, MO 63124
email:
bill@cooperlawstl.com
January 10, 2024
Ms. Sondra Snyder
United States Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549
Re: Strata Power Corporation
Form 20-F for the Fiscal Year ended December
31, 2022
Filed: March 23, 2023
File No. 000-50934
Dear Mr. Hiller:
As counsel for Strata Power Corporation.
(" Strata" or the "Company"), please be advised that we are in receipt of your comment letter dated December 20, 2023.
I have been asked to review your comments to the Form 20-F for the fiscal year ended December 31, 2022. This letter sets forth the response
of the Company to the comment by the Staff of the Office of Natural Resources of the Securities and Exchange Commission (''SEC")
with respect to the above-referenced Form 20-F filing. The references to the comment letter have been shown in bold face for convenience,
and the Company's responses are set forth below the reference.
Comment:
Form 20-F for the Fiscal Year ended December
31, 2022
General
1. We note that you have been filing various documents on SEDAR for an extended period of time, including the
last three fiscal years, such as quarterly interim financial reports, Management's Discussion and Analysis of Financial Condition and
Results of Operations, certifications by your CEO and CFO, and oil and gas disclosure reports, although you have not filed these documents
with the SEC on Form 6-K.
General Instruction B to Form 6-K requires
that you promptly furnish material information on Form 6-K that you make public or are required to make public pursuant to laws of the
jurisdiction of domicile or in which you are incorporated or organized, and is applicable pursuant to Rule 13a-16 of Regulation 13A. This
requirement also applies to material information that you file or are required to file with a stock exchange on which your securities
are traded that is made public, or that you distribute or are required to distribute to your security holders.
Please address these requirements as they
pertain to the reports that were required over the last three fiscal years and future reports that will be required on Form 6-K.
1
Response:
The Company has filed with the SEC a Form
6-K which includes quarterly interim financial reports, Management's Discussion and Analysis of Financial Condition and Results of Operations,
certifications by the CEO and CFO, as well as oil and gas disclosure reports for the last three fiscal years on January 10, 2024.
Financial Statements
Report of the Public Accounting Firm, page
F-2
2. We note that you filed an audit opinion covering only the last two fiscal years in your most recent annual
report. You will need to obtain and file an audit opinion, in an amendment to your annual report on Form 20-F, that also covers the earliest
of the three years presented to comply with Item 8.A.2 and 3 of Form 20-F.
Please advise us of any reasons that your
auditor did not express an opinion for the earliest of the three years in the audit opinion that you filed with your annual report.
Response:
The Company has amended the annual report
on Form 20-F to include a corrected audit opinion covering the earliest of the three years presented. The audited financial statements
included all three years, however the audit opinion covered only two years due to a clerical error by the audit firm.
If you have additional questions
or comments, please feel free to contact the undersigned.
Sincerely,
/s/ William E. Cooper
William E. Cooper
cc: Strata Power Corporation
2