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SEC Comment Letter for Ambow Education Holding Ltd. (AMBO) (CIK 0001494558) (AMBO) — Jul 18, 2013

Ambow Education Holding Ltd. (AMBO) (CIK 0001494558)
Date: July 18, 2013 · CIK: 0001494558 · Accession: 0000000000-13-039242

Regulatory Compliance Financial Reporting Internal Controls

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
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Summary

Reasoning

Referenced dates: January 31, 2013

Date
December 31, 2011
Author
/s/ Celeste M. Murphy for
Form
UPLOAD
Company
Ambow Education Holding Ltd. (AMBO) (CIK 0001494558)

Letter

July 18 , 2013 Via E -mail Jin Huang President and Chief Executive Officer Ambow Education Holding Ltd. 18th Floor, Building A Chengjian Plaza, No. 18 BeiTaiPingZhuang Rd, Haidian District Beijing PRC 1000088

Re: Ambow Education Holding Ltd. Form 20 -F for fiscal year ended December 31, 2011 Filed May 29, 2012 File No. 001 -34824

Dear Dr. Huang:

We issued comments to you on the above captioned filing on December 21, 2012, February 15, 2013, April 4, 2013 and May 17, 2013 . In response to our comments, you submitted response letters dated January 31, 2013, March 18, 2013, May 2, 2013 and May 31, 2013 which included proposed disclosure to be included in an amendment to your Form 20 -F for fiscal year ended December 31, 2011. On July 2 , 2013 , we issued a follow -up letter informing you that the amendment to your Form 20 -F for fiscal year ended December 31, 2011 had yet to be filed and absent a substantive response, we would act consiste nt with our obligations under the federal securities laws.

As you have not provided a substantive response, we are terminating our review and will take further steps as we deem appropriate. These steps will include our releasing all correspondence relating to our review on the EDGAR system.

You may contact Dean Suehiro, Staff Accountant , at (202) 551 -3384 , or Robert Littlepage, Accountant Branch Chief , at (202) 551 -3361 if you have questions regarding comments on the financial statements and relate d matters. Please contact Reid Hooper , Attorney -Adviso r, at (202) 551 -3359, or Celeste M. Murphy, Legal Branch Chief , at (202) 551 - 3257 with any other questions.

Sincerely,
/s/ Celeste M. Murphy for

Show Raw Text
July 18 , 2013

Via E -mail
Jin Huang
President and Chief Executive Officer
Ambow Education Holding Ltd.
18th Floor, Building A
Chengjian Plaza, No. 18
BeiTaiPingZhuang Rd, Haidian District
Beijing PRC 1000088

Re: Ambow Education Holding Ltd.
 Form 20 -F for fiscal year ended December 31, 2011
Filed May 29, 2012
File No. 001 -34824

Dear Dr. Huang:

We issued comments to you on the above captioned filing on December 21, 2012,
February  15, 2013, April 4, 2013 and May 17, 2013 .  In response to our comments, you
submitted response letters dated January 31, 2013, March 18, 2013, May 2, 2013 and May 31,
2013 which included proposed disclosure to be included in an amendment to your Form 20 -F for
fiscal year ended December 31, 2011.  On July 2 , 2013 , we issued a follow -up letter informing
you that  the amendment to your Form 20 -F for fiscal year ended December 31, 2011 had yet to
be filed  and absent a substantive response, we would act consiste nt with our obligations under
the federal securities laws.

 As you have not provided a substantive response, we are terminating our review and will
take further steps as we deem appropriate.  These steps will include our releasing all
correspondence relating to our review on the EDGAR system.

You may contact Dean Suehiro, Staff Accountant , at (202) 551 -3384 , or Robert
Littlepage, Accountant Branch Chief , at (202) 551 -3361 if you have questions regarding
comments on the financial statements and relate d matters.  Please contact Reid Hooper ,
Attorney -Adviso r, at (202) 551 -3359, or Celeste M. Murphy, Legal Branch Chief , at (202) 551 -
3257 with any other questions.

Sincerely,

 /s/ Celeste M. Murphy for

 Larry Spirgel
Assistant Director

Jin Huan g
Ambow Education Holding Ltd.
July 18 , 2013
Page 2

cc: Via E -mail
 Steve Lin, Esq.