SEC Comment Letter for ALPHA & OMEGA SEMICONDUCTOR Ltd (AOSL) (CIK 0001387467) (AOSL) — Jan 27, 2017
ALPHA & OMEGA SEMICONDUCTOR Ltd (AOSL) (CIK 0001387467)
Date: Jan. 27, 2017 · CIK: 0001387467 · Accession: 0000000000-17-003051
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3030 January 2 7, 2017 Via E -mail Mr. Yifan Liang Chief Financial Officer Alpha and Omega Semiconductor Limited Clarendon House 2 Church Street Hamilton HM 11, Bermuda
Re: Alpha and Omega Semiconductor Limited Form 10-K for the Fiscal Year Ended June 30 , 2016 Filed August 26 , 2016 File No. 001 -34717
Dear Mr. Liang :
We have reviewed your filing and have the following comment . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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 comm ent applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments.
Form 10 -K for the Fiscal Year Ended June 30, 2016
Item 9A. Management’s Annual Report on Internal Control over Financial Reporting, page 57
1. Please amend your filing to include a statement identifying the framework used by management to evaluate the effectiveness of your internal control over financial reporting - e.g., COSO framework (2013). In addition, revise the report to include management’s conclusion on the effectiveness of your internal control over financial reporting as of the end of the period, including a clear statement as to whether or not internal control over financial reporting is effective. Refer to Items 308(a)(2) and (3) of Regulation S -K.
Yifan Liang Alpha and Omega Semiconductor Limited January 2 7, 2017 Page 2
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 Julie Sherman at (202) 551 -3640 or me at (202) 551 -3676 if you have any questions regarding comments on the financial statements and related matters. Please contact Tom Jones at (202) 551 -3602 or Geoffrey Kruczek, Senior Attorney, at (202) 551 -3641 with any other questions.
Sincerely,
/s/ Brian Cascio
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Mail Stop 3030 January 2 7, 2017 Via E -mail Mr. Yifan Liang Chief Financial Officer Alpha and Omega Semiconductor Limited Clarendon House 2 Church Street Hamilton HM 11, Bermuda Re: Alpha and Omega Semiconductor Limited Form 10-K for the Fiscal Year Ended June 30 , 2016 Filed August 26 , 2016 File No. 001 -34717 Dear Mr. Liang : We have reviewed your filing and have the following comment . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comm ent applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Form 10 -K for the Fiscal Year Ended June 30, 2016 Item 9A. Management’s Annual Report on Internal Control over Financial Reporting, page 57 1. Please amend your filing to include a statement identifying the framework used by management to evaluate the effectiveness of your internal control over financial reporting - e.g., COSO framework (2013). In addition, revise the report to include management’s conclusion on the effectiveness of your internal control over financial reporting as of the end of the period, including a clear statement as to whether or not internal control over financial reporting is effective. Refer to Items 308(a)(2) and (3) of Regulation S -K. Yifan Liang Alpha and Omega Semiconductor Limited January 2 7, 2017 Page 2 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 Julie Sherman at (202) 551 -3640 or me at (202) 551 -3676 if you have any questions regarding comments on the financial statements and related matters. Please contact Tom Jones at (202) 551 -3602 or Geoffrey Kruczek, Senior Attorney, at (202) 551 -3641 with any other questions. Sincerely, /s/ Brian Cascio Brian Cascio Accounting Branch Chief Office of Electronics and Machinery