SEC Comment Letter for ENVIRONMENTAL CONTROL CORP. (YBCN) (CIK 0001284454) (NFSN) — Jan 9, 2020
ENVIRONMENTAL CONTROL CORP. (YBCN) (CIK 0001284454)
Date: Jan. 9, 2020 · CIK: 0001284454 · Accession: 0000000000-20-000225
AI Filing Summary & Sentiment
File numbers found in text: 000-56129
Letter
January 8, 2020 Chang Qi President Environmental Control Corp. Apt 1-1-2 Bawangsi Street Dadong District Shenyang 110000 Re:Environmental Control Corp. Registration Statement on Form 10-12G Filed December 12, 2019 File No. 000-56129 Dear Ms. Qi: We have reviewed your filing 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 and any amendment you may file in response to these comments, we may have additional comments. Form 10-12G filed on December 12, 2019 History, page 2 1.Please expand the disclosure in the sixth paragraph on page 2 to disclose and quantify the expenses of the company that Mr. Glass paid in his capacity as custodian. 2.Please expand the disclosure in the eighth paragraph on page 2 to disclose the amount that Chang Qi paid to acquire the shares from Mr. Glass. 3.In the fourth paragraph, you disclose that Mr. Glass appointed himself as President. In the sixth paragraph, you disclose that the board of directors appointed Mr. Glass as President. Please reconcile. 4.Please revise to clarify the circumstances that led to Mr. Glass being appointed as custodian of the company. Please also revise to clarify the circumstances that led to Mr. Glass selling his shares to Chang Qi.
FirstName LastNameChang Qi Comapany NameEnvironmental Control Corp. January 8, 2020 Page 2 FirstName LastName Chang Qi Environmental Control Corp. January 8, 2020 Page 2 Risk Factors, page 9 5.If applicable, please disclose the risk that, because your officer and director reside outside the United States, investors may have limited legal recourse against them including difficulties in enforcing judgments made against them by U.S. courts. Exhibits 6.Please file as exhibits the custodial order and the Certificate of Reinstatement with the State of Nevada mentioned in the fourth and fifth paragraphs on page 2, respectively. 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. You may contact Melissa Gilmore at 202-551-3777 or Claire Erlanger, Senior Accountant, at 202-551-3301 if you have questions regarding comments on the financial statements and related matters. Please contact Thomas Jones at 202-551-3602 or Geoffrey Kruczek, Senior Attorney, at 202-551-3641 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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January 8, 2020
Chang Qi
President
Environmental Control Corp.
Apt 1-1-2 Bawangsi Street
Dadong District Shenyang 110000
Re:Environmental Control Corp.
Registration Statement on Form 10-12G
Filed December 12, 2019
File No. 000-56129
Dear Ms. Qi:
We have reviewed your filing 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 and any amendment you may file in response to these
comments, we may have additional comments.
Form 10-12G filed on December 12, 2019
History, page 2
1.Please expand the disclosure in the sixth paragraph on page 2 to disclose and quantify the
expenses of the company that Mr. Glass paid in his capacity as custodian.
2.Please expand the disclosure in the eighth paragraph on page 2 to disclose the amount that
Chang Qi paid to acquire the shares from Mr. Glass.
3.In the fourth paragraph, you disclose that Mr. Glass appointed himself as President. In the
sixth paragraph, you disclose that the board of directors appointed Mr. Glass as President.
Please reconcile.
4.Please revise to clarify the circumstances that led to Mr. Glass being appointed as
custodian of the company. Please also revise to clarify the circumstances that led to Mr.
Glass selling his shares to Chang Qi.
FirstName LastNameChang Qi
Comapany NameEnvironmental Control Corp.
January 8, 2020 Page 2
FirstName LastName
Chang Qi
Environmental Control Corp.
January 8, 2020
Page 2
Risk Factors, page 9
5.If applicable, please disclose the risk that, because your officer and director reside outside
the United States, investors may have limited legal recourse against them including
difficulties in enforcing judgments made against them by U.S. courts.
Exhibits
6.Please file as exhibits the custodial order and the Certificate of Reinstatement with the
State of Nevada mentioned in the fourth and fifth paragraphs on page 2, respectively.
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.
You may contact Melissa Gilmore at 202-551-3777 or Claire Erlanger, Senior
Accountant, at 202-551-3301 if you have questions regarding comments on the financial
statements and related matters. Please contact Thomas Jones at 202-551-3602 or Geoffrey
Kruczek, Senior Attorney, at 202-551-3641 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing