SEC Company Response from Scepter Holdings, Inc. NV (CIK 0001420924) (ADTI) — Dec 15, 2010
Scepter Holdings, Inc. NV (CIK 0001420924)
Date: Dec. 15, 2010 · CIK: 0001420924 · Accession: 0001096350-10-000158
AI Filing Summary & Sentiment
Reasoning
Referenced dates: November 30, 2010
Letter
Form 10-K/A for Fiscal Year Ended March 31, 2010
Brazos International Exploration, Inc.
1660 NW Pompano Beach Florida 33069
December 14, 2010
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street
Washington D.C. 20549
Re: Brazos International Exploration, Inc.
Attention Suying Li
We are writing in response to your comments dated November 30, 2010
Form 10-K/A for Fiscal Year Ended March 31, 2010
Item 9A (T): Controls & Procedures
1. Management's Report on Internal Control over Financial Reporting
It does not appear that your management has performed its assessment of internal control over financial reporting as of March 31, 2010. Since you were required to file an annual report for or the prior fiscal year, it appears you are required to report on your management's assessment of internal control over financial reporting pursuant to Item )308T of Regulation S-K. Also refer to the guidance at Release 33-8934.
If your management has not yet performed its assessment, we ask that you complete your evaluation and amend your filing within 30 calendar days to provide the required management report on internal control over financial reporting.
We have provided this in our amended 10K/A filed December 14, 2010
Exhibits 31 and 32
2. It does not appear that the appropriate individuals signed the certifications required by Exchange Act Rule 13a-14(a) or 15(1-14(a.) and Exchange Act Rule 13a-,4(b) or 15d-14(b), Please note that these certifications must be signed by your principal executive
officer and principal financial officer as of the filing date. Please revise. Refer to Item
601(B)(31) and Item 601 (B)(32) of Regulation S-K.
This comment also applies to the certifications filed with your Form 10-Q for the quarterly period ended September 30, 2010.
We have provided all certifications with respect our Amended 10-K and our Amended 10 -Q and are signed by the appropriate officers of the company.
Form 10-Q For Fiscal Quarter Ended September 30, 2010
Item 4T: Controls and Procedures
Evaluation of Disclosure Controls and Procedures
3. It appears you have provided management's conclusion regarding the effectiveness of your disclosure controls and procedures as of September 30, 2008. Please revise to provide management's conclusion regarding the effectiveness of your disclosure controls and procedures as of the end of the period covered by this report (i.e. September 30, 2010).
We have revised this section to reflect the proper date being September 30, 2010
Yours truly,
/s/ Samuel Weiss
Samuel Weiss
President , CEO
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Form 10-K/A for Fiscal Year Ended March 31, 2010
Brazos International Exploration, Inc.
1660 NW Pompano Beach Florida 33069
December 14, 2010
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street
Washington D.C. 20549
Re: Brazos International Exploration, Inc.
Attention Suying Li
We are writing in response to your comments dated November 30, 2010
Form 10-K/A for Fiscal Year Ended March 31, 2010
Item 9A (T): Controls & Procedures
1. Management's Report on Internal Control over Financial Reporting
It does not appear that your management has performed its assessment of internal control over financial reporting as of March 31, 2010. Since you were required to file an annual report for or the prior fiscal year, it appears you are required to report on your management's assessment of internal control over financial reporting pursuant to Item )308T of Regulation S-K. Also refer to the guidance at Release 33-8934.
If your management has not yet performed its assessment, we ask that you complete your evaluation and amend your filing within 30 calendar days to provide the required management report on internal control over financial reporting.
We have provided this in our amended 10K/A filed December 14, 2010
Exhibits 31 and 32
2. It does not appear that the appropriate individuals signed the certifications required by Exchange Act Rule 13a-14(a) or 15(1-14(a.) and Exchange Act Rule 13a-,4(b) or 15d-14(b), Please note that these certifications must be signed by your principal executive
officer and principal financial officer as of the filing date. Please revise. Refer to Item
601(B)(31) and Item 601 (B)(32) of Regulation S-K.
This comment also applies to the certifications filed with your Form 10-Q for the quarterly period ended September 30, 2010.
We have provided all certifications with respect our Amended 10-K and our Amended 10 -Q and are signed by the appropriate officers of the company.
Form 10-Q For Fiscal Quarter Ended September 30, 2010
Item 4T: Controls and Procedures
Evaluation of Disclosure Controls and Procedures
3. It appears you have provided management's conclusion regarding the effectiveness of your disclosure controls and procedures as of September 30, 2008. Please revise to provide management's conclusion regarding the effectiveness of your disclosure controls and procedures as of the end of the period covered by this report (i.e. September 30, 2010).
We have revised this section to reflect the proper date being September 30, 2010
Yours truly,
/s/ Samuel Weiss
Samuel Weiss
President , CEO