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SEC Comment Letter for PRIME GLOBAL CAPITAL GROUP Inc (CIK 0001462047) — Mar 16, 2020

PRIME GLOBAL CAPITAL GROUP Inc (CIK 0001462047)
Date: March 16, 2020 · CIK: 0001462047 · Accession: 0000000000-20-002355

AI Filing Summary & Sentiment

File numbers found in text: 000-54288

Date
March 16, 2020
Author
Not clearly detected
Form
UPLOAD
Company
PRIME GLOBAL CAPITAL GROUP Inc (CIK 0001462047)

Letter

March 16, 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 reviewed your March 16, 2020 response to our comment letter 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. Unless we note otherwise, our references to prior comment is to our comment in our March 11, 2020 letter. FORM 10-K FOR THE YEAR ENDED OCTOBER 31, 2019 Report Of Independent Registered Public Accounting Firm, page F-1 1.We have considered your response and will monitor your amended 10-K when filed for the inclusion of the revised audit opinion language as outlined within Exhibit A. You may contact Peter McPhun, Staff Accountant, at 202-551-3581 or Wilson K. Lee, Senior Staff Accountant, at 202-551-3468 if you have questions regarding our comment on the financial statements and related matters. Sincerely,

FirstName LastNameWeng Kung Wong Comapany NamePrime Global Capital Group Incorporated March 16, 2020 Page 2 FirstName LastName Weng Kung Wong Prime Global Capital Group Incorporated March 16, 2020 Page 2 Division of Corporation Finance Office of Real Estate & Construction

Show Raw Text
March 16, 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 reviewed your March 16, 2020 response to our comment letter 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.  Unless we note otherwise, our references to prior comment is to our comment in our
March 11, 2020 letter.
FORM 10-K FOR THE YEAR ENDED OCTOBER 31, 2019
Report Of Independent Registered Public Accounting Firm, page F-1
1.We have considered your response and will monitor your amended 10-K when filed for
the inclusion of the revised audit opinion language as outlined within Exhibit A.
            You may contact Peter McPhun, Staff Accountant, at 202-551-3581 or Wilson K. Lee,
Senior Staff Accountant, at 202-551-3468 if you have questions regarding our comment on the
financial statements and related matters.
Sincerely,

 FirstName LastNameWeng Kung Wong
 Comapany NamePrime Global Capital Group Incorporated
 March 16, 2020 Page 2
 FirstName LastName
Weng Kung Wong
Prime Global Capital Group Incorporated
March 16, 2020
Page 2
Division of Corporation Finance
Office of Real Estate & Construction