SecProbe.io

CORRESP
1
filename1.htm

    Advanced
        Biomedical Technologies, INC.

        350
        5th Ave. FL59, New York, NY 10118

        Tel:
        (718)-766 7898 E-mail: info@abtbiomedical.com

    May
    5, 2020

Via
EDGAR

Division
of Corporate Finance

Office
of Life Sciences

United
States Securities and Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Attention:
    Ms.
    Tara L. Harkins, Staff Accountant

    Mr.
    Kevin J. Kuhar, Accounting Branch Chief

Re:
Advanced Biomedical Technologies, Inc.

Form
10-K for the Fiscal Year Ended October 31, 2019

Filed
March 20, 2020

File
No. 000-53051

Ladies
and Gentlemen:

We
have received a letter dated April 29, 2020 from Securities Exchange Commission; we have made our response concerning your question
as below:

    1.
    We
    note that you have concluded your internal control over financial reporting was not effective as of October 31, 2019. Consistent
    with item 308(a)(3) of Regulation S-K, please describe to us the material weakness in your internal control over financial
    reporting and revise future filings to disclose them.

      Page 1

REPONSE:
We have revised our internal control over financial reporting on our latest Form 10-Q report filed on April 30, 2020 which
described the material weakness in our internal control over financial reporting. The related contents are as below:

Evaluation
of Disclosure Controls and Procedures

We
have established disclosure controls and procedures, as such term is defined in Rule 13a-15(e) under the Securities Exchange Act
of 1934. Our disclosure controls and procedures are designed to ensure that material information relating to us, including our
consolidated subsidiaries, is made known to our principal executive officer and principal financial officer by others within our
organization. Under the supervision and with the participation of our management, including our principal executive officer and
principal financial officer, we conducted an evaluation of the effectiveness of our disclosure controls and procedures as of January
31, 2020 to ensure that the information required to be disclosed by us in the reports that we file or submit under the Securities
Exchange Act of 1934 is recorded, processed, summarized, and reported within the time periods specified in the SEC’s rules
and forms. Disclosure controls and procedures include, without limitation, controls and procedures designed to ensure that information
required to be disclosed by us in the reports that we file or submit under the Securities Exchange Act of 1934 is accumulated
and communicated to our management, including our principal executive officer and principal financial officer as appropriate,
to allow timely decisions regarding required disclosure. Based on this evaluation, our principal executive officer and principal
financial officer concluded that our disclosure controls and procedures were not effective as of January 31, 2020.

Under
the supervision and with the participation of our then principal executive officer and principal financial officer, we conducted
an evaluation of our disclosure controls and procedures, as such term is defined under Rule 13a-15(e) and Rule 15d-15(e) promulgated
under the Securities Exchange Act of 1934, as amended, as of January 31, 2020. Based on this evaluation, the management concluded
that the disclosure controls and procedures were ineffective at such time to ensure that information required to be disclosed
by the company in the reports filed or submitted under the Exchange Act were recorded, processed, summarized and reported within
the time periods specified in the Securities and Exchange Commission’s rules and forms. Our principal executive officer
and principal financial officer also concluded that our disclosure controls, which are designed to ensure that information required
to be disclosed by us in the reports that we file or submit under the Exchange Act is accumulated and communicated to management,
were inappropriate to allow timely decisions regarding required disclosure.

Based
on officers’ assessment, the Company determined that there were material weaknesses in its internal control over financial
reporting as of January 31, 2020 based on the material weaknesses described below:

●
Because the Company consists of one person who acts as the financial officer, operating officer, secretary and director of the
Company, there are limited controls over information processing.

●
There is an inadequate segregation of duties consistent with control objectives as financial reporting function is composed of
only one person. In order to remedy this situation, we would need to hire additional staff to provide greater segregation of duties.
Currently, it is not feasible to hire additional staff to obtain optimal segregation of duties. Management will reassess this
matter after the Company has obtained additional financial resources to determine whether improvement in segregation of duty is
feasible.

      Page 2

●
The Company does not have a formal audit committee with a financial expert, and thus the Company lacks the Board oversight role
within the financial reporting process.

●
There is a lack of formal policies and procedures necessary to adequately review significant accounting transactions.

The
Company utilizes a third-party independent contractor for the preparation of its financial statements. Although the financial
statements and footnotes are reviewed by our management, we do not have a formal policy to review significant accounting transactions
and the accounting treatment of such transactions. The third-party independent contractor is not involved in the day to day operations
of the Company and may not provide financial information from and to the management on a timely basis to allow for adequate reporting/consideration
of certain transactions.

As
a result of the above material weaknesses, our management concluded that our internal control over financial reporting was not
effective as of January 31, 2020. A material weakness is a deficiency, or a combination of deficiencies, in internal control over
financial reporting, such that there is a reasonable possibility that a material misstatement of our annual or interim financial
statements will not be prevented or detected on a timely basis. A significant deficiency is a deficiency, or a combination of
deficiencies, in internal control over financial reporting that is less severe than a material weakness; yet important enough
to merit attention by those responsible for oversight of the company’s financial reporting.

If
you have further questions, do not hesitate to let us know.

    Very
    truly yours,

    /s/
    Kai Gui

    Kai
    Gui, Chief Financial Officer

    Advance
    Biomedical Technologies, Inc.

    cc:
    Andrew
    Befumo, Esq.

    LAI,
    Wing Wai, Esq.

    Wayne
    Tang, Esq.

      Page 3