SEC Comment Letter 0000000000-23-008799 to Concord Medical Services Holdings Ltd (CCM)
Concord Medical Services Holdings Ltd
Date: Aug. 11, 2023 · CIK: 0001472072 · Accession: 0000000000-23-008799
AI Filing Summary & Sentiment
File numbers found in text: 001-34563
Referenced dates: July 14, 2023
Letter
United States securities and exchange commission logo August 11, 2023 Boxun Zhang Chief Financial Officer Room 2701-05, Tower A, Global Trade Center 36 North Third Ring Road, Dongcheng District Beijing 100013 People’s Republic of China Re:Concord Medical Services Holdings Ltd Form 20-F Response Dated July 14, 2023 File No. 001-34563 Dear Boxun Zhang: We have reviewed your July 14, 2023 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our June 29, 2023 letter. Response Letter dated July 14, 2023 General 1.We note your proposed disclosure in response to comment 4, including that "in connection with our historical issuance of securities to foreign investors, under currently effective PRC laws, regulations, and regulatory rules, as of the date of this annual report, we (1) are not required to obtain permissions from the China Securities Regulatory Commission (the “CSRC”), (2) are not required to proactively go through cybersecurity review by the Cyberspace Administration of China (the “CAC”), and (3) have not been requested to obtain such permissions by any PRC authority." Please revise to clarify whether you relied upon an opinion of counsel with respect to your proposed disclosure that you are not required to obtain permissions from the CSRC and are not required to complete a
FirstName LastNameBoxun Zhang Comapany NameRoom 2701-05, Tower A, Global Trade Center August 11, 2023 Page 2 FirstName LastName Boxun Zhang Room 2701-05, Tower A, Global Trade Center August 11, 2023 Page 2 cybersecurity review by the CAC. You may contact Jeanne Baker at (202) 551-3691 or Terence O'Brien at (202) 551- 3355 if you have questions regarding comments on the financial statements and related matters. Please contact Katherine Bagley at (202) 551-2545 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
Show Raw Text
United States securities and exchange commission logo
August 11, 2023
Boxun Zhang
Chief Financial Officer
Room 2701-05, Tower A, Global Trade Center
36 North Third Ring Road, Dongcheng District
Beijing 100013
People’s Republic of China
Re:Concord Medical Services Holdings Ltd
Form 20-F
Response Dated July 14, 2023
File No. 001-34563
Dear Boxun Zhang:
We have reviewed your July 14, 2023 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
June 29, 2023 letter.
Response Letter dated July 14, 2023
General
1.We note your proposed disclosure in response to comment 4, including that "in connection
with our historical issuance of securities to foreign investors, under currently effective
PRC laws, regulations, and regulatory rules, as of the date of this annual report, we (1) are
not required to obtain permissions from the China Securities Regulatory Commission (the
“CSRC”), (2) are not required to proactively go through cybersecurity review by the
Cyberspace Administration of China (the “CAC”), and (3) have not been requested to
obtain such permissions by any PRC authority." Please revise to clarify whether you
relied upon an opinion of counsel with respect to your proposed disclosure that you are
not required to obtain permissions from the CSRC and are not required to complete a
FirstName LastNameBoxun Zhang
Comapany NameRoom 2701-05, Tower A, Global Trade Center
August 11, 2023 Page 2
FirstName LastName
Boxun Zhang
Room 2701-05, Tower A, Global Trade Center
August 11, 2023
Page 2
cybersecurity review by the CAC.
You may contact Jeanne Baker at (202) 551-3691 or Terence O'Brien at (202) 551-
3355 if you have questions regarding comments on the financial statements and related
matters. Please contact Katherine Bagley at (202) 551-2545 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services