SecProbe.io

March 5, 2020
Weng Kung Wong
Chief Financial Officer
Prime Global Capital Group Incorporated
E-5-2 Megan Avenue 1, Block E
Jalan Tun Razak
50400 Kuala Lumpur, Malaysia
Re:Prime Global Capital Group Incorporated
Form 10-K for the fiscal year ended October 31, 2019
Filed February 3, 2020
File No. 000-54288
Dear Mr. Wong:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
FORM 10-K FOR THE YEAR ENDED OCTOBER 31, 2019
Report Of Independent Registered Public Accounting Firm, page F-1
1.We could not locate an audit opinion that covers the financial statements as of October 31,
2018 and the year ended October 31, 2018.   Please revise to include an audit opinion that
covers all periods required pursuant to Rule 8-02 of Regulation S-X.
2.We note that the format and components of the audit opinion provided does not appear to
conform to all the requirements outlined within paragraphs 5 to 10 of PCAOB Auditing
Standard 3101.   Please request a revised audit opinion from your independent registered
public accounting firm and revise your filing to include such conforming audit opinion.
            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 LastNameWeng Kung Wong
 Comapany NamePrime Global Capital Group Incorporated
 March 5, 2020 Page 2
 FirstName LastName
Weng Kung Wong
Prime Global Capital Group Incorporated
March 5, 2020
Page 2
            You may contact Peter McPhun, Staff Accountant, at (202) 551-3581 or Wilson K. Lee,
Senior Staff Accountant, at (202) 551-3468 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction