SEC Comment Letter for Scepter Holdings, Inc. NV (CIK 0001420924) (ADTI) — Sep 3, 2009
Scepter Holdings, Inc. NV (CIK 0001420924)
Date: Sept. 3, 2009 · CIK: 0001420924 · Accession: 0000000000-09-048712
AI Filing Summary & Sentiment
Reasoning
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4628 DIVISION OF CORPORATION FINANCE September 2, 2009 Via U.S. Mail and Facsimile (646) 415-9093 Mr. David J. Keating President Brazos International Exploration, Inc. 2819 Fort Hamilton Parkway Brooklyn, NY 11218 Re: Brazos International Exploration, Inc. Form 10-K for the Fiscal Year Ended March 31, 2009 Filed July 15, 2009 Item 4.01 Form 8-K Filed August 6, 2009 File No. 0-53336
Dear Mr. Keating: Your most recent Form 10-K includes financial statements audited by Moore and Associates Chartered (“Moore”). On A ugust 27, 2009, the Public Company Accounting Oversight Board ("PCAOB") revoked the registra tion of Moore because of violations of PCAOB rules and auditing standards in audi ting the financial statements, PCAOB rules and quality controls standard s, and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and noncooperation with a Board investigation. You can find a copy of the order at: http://www.pcaobus.org/Enforcement/Disci plinary_Proceedings /2009/08-27_Moore.pdf
As Moore is no longer registered with the PCAOB, you may not include Moore’s audit reports or consents in your filings with the Commi ssion made on or after August 27, 2009. If Moore audited a year that you are re quired to include in your filings with the Commission, then you should engage a firm that is registered with the PCAOB to re- audit that year. Please amend your Item 4.01 Form 8-K, filed August 6, 2009, to disclose that the PCAOB revoked the registration of Moore on August 27, 2009 because of violations of PCAOB rules and auditing standards in audi ting the financial statements, PCAOB rules and quality controls standard s, and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and noncoope ration with a Board investigation.
Mr. David J. Keating Brazos International Exploration, Inc. September 2, 2009 Page 2 If you are unable to obtain an Exhibit 16 letter from Moore at the time you file your Form 8-K – or an amended Exhibit 16 letter for an amended Form 8-K – please disclose this fact in the Form 8-K.
Once you explain Moore’s registration revoc ation in an Item 4.01 Form 8-K, you do not need to repeat this disclo sure in your next Form 10-K. Any amendment to Form 8-K should be file d within four business days of receipt of this letter. Please advise us as to ho w you intend to address any re-audit requirements no later than September 11, 2009. If you have any questions, I can be reached at 202- 551-3461. Sincerely, / s / C h r i s W h i t e C h r i s W h i t e B r a n c h C h i e f
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4628
DIVISION OF
CORPORATION FINANCE
September 2, 2009 Via U.S. Mail and Facsimile (646) 415-9093
Mr. David J. Keating President Brazos International Exploration, Inc. 2819 Fort Hamilton Parkway Brooklyn, NY 11218
Re: Brazos International Exploration, Inc.
Form 10-K for the Fiscal Year Ended March 31, 2009
Filed July 15, 2009
Item 4.01 Form 8-K
Filed August 6, 2009
File No. 0-53336
Dear Mr. Keating: Your most recent Form 10-K includes financial statements audited by Moore and Associates Chartered (“Moore”). On A ugust 27, 2009, the Public Company Accounting
Oversight Board ("PCAOB") revoked the registra tion of Moore because of violations of
PCAOB rules and auditing standards in audi ting the financial statements, PCAOB rules
and quality controls standard s, and Section 10(b) of the Securities Exchange Act of 1934
and Rule 10b-5 thereunder, and noncooperation with a Board investigation. You can find
a copy of the order at: http://www.pcaobus.org/Enforcement/Disci plinary_Proceedings /2009/08-27_Moore.pdf
As Moore is no longer registered with the PCAOB, you may not include Moore’s
audit reports or consents in your filings with the Commi ssion made on or after August 27,
2009. If Moore audited a year that you are re quired to include in your filings with the
Commission, then you should engage a firm that is registered with the PCAOB to re-
audit that year. Please amend your Item 4.01 Form 8-K, filed August 6, 2009, to disclose that the
PCAOB revoked the registration of Moore on August 27, 2009 because of violations of
PCAOB rules and auditing standards in audi ting the financial statements, PCAOB rules
and quality controls standard s, and Section 10(b) of the Securities Exchange Act of 1934
and Rule 10b-5 thereunder, and noncoope ration with a Board investigation.
Mr. David J. Keating
Brazos International Exploration, Inc. September 2, 2009 Page 2
If you are unable to obtain an Exhibit 16 letter from Moore at the time you file
your Form 8-K – or an amended Exhibit 16 letter for an amended Form 8-K – please
disclose this fact in the Form 8-K.
Once you explain Moore’s registration revoc ation in an Item 4.01 Form 8-K, you
do not need to repeat this disclo sure in your next Form 10-K.
Any amendment to Form 8-K should be file d within four business days of receipt
of this letter. Please advise us as to ho w you intend to address any re-audit requirements
no later than September 11, 2009. If you have any questions, I can be reached at 202-
551-3461.
Sincerely,
/ s / C h r i s W h i t e C h r i s W h i t e
B r a n c h C h i e f