SEC Comment Letter for RYVYL Inc. (RTB) (CIK 0001419275) (RTB) — Dec 31, 2019
RYVYL Inc. (RTB) (CIK 0001419275)
Date: Dec. 31, 2019 · CIK: 0001419275 · Accession: 0000000000-19-016869
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December 31, 2019
Fredi Nisan
Chief Executive Officer
GreenBox POS
8880 Rio San Diego Drive, Suite 102
San Diego, California 92108
Re:GreenBox POS
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed April 16, 2019
File No. 1-34294
Dear Mr. Nisan:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, 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
comment 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 December 31, 2018
Signatures, page 20
1.Please revise to have your principal financial officer and principal accounting officer or
controller and the majority of the board of directors sign the report in their individual
capacities. These signatures should appear in a second signature block of the signature
section. If someone has signed in more than one capacity, indicate each capacity in which
he or she has signed. Refer to Instruction (D)(2) to Form 10-K.
In closing, 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.
FirstName LastNameFredi Nisan
Comapany NameGreenBox POS
December 31, 2019 Page 2
FirstName LastName
Fredi Nisan
GreenBox POS
December 31, 2019
Page 2
You may contact Ta Tanisha Meadows at (202) 551-3322 or Bill Thompson at (202)
551-3344 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services