SEC Comment Letter for Hypha Labs, Inc. (FUNI) (CIK 0001502966) (FUNI) — Feb 1, 2017
Hypha Labs, Inc. (FUNI) (CIK 0001502966)
Date: Feb. 1, 2017 · CIK: 0001502966 · Accession: 0000000000-17-003548
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3233 February 1, 2017 Via E -mail Mr. Todd A. Peterson Chief Financial Officer Digipath, Inc. 6450 Cameron Street, Suite 113 Las Vegas, NV 89118
Re: Digipath, Inc. Form 10-K for the Fiscal Year Ended September 30, 2016 Filed January 9, 2017 File No. 000 -54239
Dear Mr. Peterson :
We have limited our review of your filing to the financial statements and related disclosures 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 busine ss days by providing the requested information or advis e 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.
Item 9A. Controls and Procedures
Management’s Report on I nternal Control over Financial Reporting, page 25
1. We note that management assessed your internal control over financial reporting using the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) in Internal Contr ol Integrated Framework. Please tell us and revise future filings to disclose whether you applied the 1992 or 2013 COSO framework in your assessment. Reference is made to Item 308(a)(2) of Regulation S -K.
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.
Mr. Todd A. Peterson Digipath, Inc. February 1, 2017 Page 2
You may contact Isaac Esquivel, Staff Accountant , at (202) 551 -3395 or Shannon Sobotka, Staff Accountant at (202) 551 -3856 with any questions.
Sincerely,
/s/ Shannon Sobotka
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Mail Stop 3233 February 1, 2017 Via E -mail Mr. Todd A. Peterson Chief Financial Officer Digipath, Inc. 6450 Cameron Street, Suite 113 Las Vegas, NV 89118 Re: Digipath, Inc. Form 10-K for the Fiscal Year Ended September 30, 2016 Filed January 9, 2017 File No. 000 -54239 Dear Mr. Peterson : We have limited our review of your filing to the financial statements and related disclosures 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 busine ss days by providing the requested information or advis e 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. Item 9A. Controls and Procedures Management’s Report on I nternal Control over Financial Reporting, page 25 1. We note that management assessed your internal control over financial reporting using the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) in Internal Contr ol Integrated Framework. Please tell us and revise future filings to disclose whether you applied the 1992 or 2013 COSO framework in your assessment. Reference is made to Item 308(a)(2) of Regulation S -K. 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. Mr. Todd A. Peterson Digipath, Inc. February 1, 2017 Page 2 You may contact Isaac Esquivel, Staff Accountant , at (202) 551 -3395 or Shannon Sobotka, Staff Accountant at (202) 551 -3856 with any questions. Sincerely, /s/ Shannon Sobotka Shannon Sobotka Staff Accountant Office of Real Estate and Commodities