SEC Comment Letter for Ambow Education Holding Ltd. (AMBO) (CIK 0001494558) (AMBO) — Oct 12, 2017
Ambow Education Holding Ltd. (AMBO) (CIK 0001494558)
Date: Oct. 12, 2017 · CIK: 0001494558 · Accession: 0000000000-17-036235
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Reasoning
File numbers found in text: 001-34824
Letter
Mail Stop 3720 October 1 2, 2017 Dr. Jin Huang President and Chief Executive Officer Ambow Education Holding Ltd. 12th F loor, Tower 1, Financial Street Chang’ an Center, Shijingshan District Beijing 100043 People’s Republic of China
Re: Ambow Education Holding Ltd. Form 20 -F for Fis cal Year Ended December 31, 2016 Response Dated October 3, 2017 File No. 001-34824
Dear Dr. Huang :
We have reviewed your October 3, 2017 response to our comment letter and have the following comments. Please comply with the following comments in future filings. Confirm in writing that you will do so and explain to us how you intend to comply.
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 t o these comments, we may have additional comments.
Financial Statements
Consolidated Balance Sheets, page F -3 & Consolidated Statements of Changes in Equity (Deficit), page F -7
1. We note the proposed revisions offered in your response to comment 5. Please also include an analysis of changes in each caption of stockholders’ equity and non - controlling interests in accordance with the guidance of Items 17(b) and 18(a) of Form 20-F and Rule 3 -04 of Regulation S -X.
Dr. Jin Huang Ambow Education Holding Ltd. October 1 2, 2017 Page 2
21. Segment Information, page F -46
2. We note your response to comment 8. In addition to the disclosures you propose to include in future filings, please include a reconciliation of gross profit to loss before income taxes as required by ASC 280 -10-50-30(b).
You may contact Joseph Kempf, Sta ff Accountant, at (202) 551 -3352 or Ivette Leon, Assistant Chief Accountant, at (202) 551 -3351 if you have questions regarding comments on the financial statements and related matters. Please contact William Mastrianna, Attorney -Adviser, at (202) 551 -3778 , Kathleen Krebs, Special Counsel, at (202) 551 -3350, or me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Kathleen Krebs, for
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Mail Stop 3720 October 1 2, 2017 Dr. Jin Huang President and Chief Executive Officer Ambow Education Holding Ltd. 12th F loor, Tower 1, Financial Street Chang’ an Center, Shijingshan District Beijing 100043 People’s Republic of China Re: Ambow Education Holding Ltd. Form 20 -F for Fis cal Year Ended December 31, 2016 Response Dated October 3, 2017 File No. 001-34824 Dear Dr. Huang : We have reviewed your October 3, 2017 response to our comment letter and have the following comments. Please comply with the following comments in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. 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 t o these comments, we may have additional comments. Financial Statements Consolidated Balance Sheets, page F -3 & Consolidated Statements of Changes in Equity (Deficit), page F -7 1. We note the proposed revisions offered in your response to comment 5. Please also include an analysis of changes in each caption of stockholders’ equity and non - controlling interests in accordance with the guidance of Items 17(b) and 18(a) of Form 20-F and Rule 3 -04 of Regulation S -X. Dr. Jin Huang Ambow Education Holding Ltd. October 1 2, 2017 Page 2 21. Segment Information, page F -46 2. We note your response to comment 8. In addition to the disclosures you propose to include in future filings, please include a reconciliation of gross profit to loss before income taxes as required by ASC 280 -10-50-30(b). You may contact Joseph Kempf, Sta ff Accountant, at (202) 551 -3352 or Ivette Leon, Assistant Chief Accountant, at (202) 551 -3351 if you have questions regarding comments on the financial statements and related matters. Please contact William Mastrianna, Attorney -Adviser, at (202) 551 -3778 , Kathleen Krebs, Special Counsel, at (202) 551 -3350, or me at (202) 551 -3810 with any other questions. Sincerely, /s/ Kathleen Krebs, for Larry Spirgel Assistant Director AD Office 11 – Telecommunications