SEC Comment Letter for Synergy CHC Corp. (SNYR) (CIK 0001562733) (SNYRQ) — May 12, 2014
Synergy CHC Corp. (SNYR) (CIK 0001562733)
Date: May 12, 2014 · CIK: 0001562733 · Accession: 0000000000-14-024103
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-55098
Letter
May 12, 2014 Via E-mail Mark Suponitsky Chief Executive Officer Synergy Strips Corp. 2105 Burton Branch Road Algood, TN 38506
Re: Synergy Strips Corp. Form 8 -K Filed May 7 , 2014 File No. 000-55098
Dear Mr. Suponitsky :
We have reviewed your filing an d 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 this letter within five business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstanc es or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Form 8 -K Filed on May 7 , 2014
Change in Accountant
1. When a reverse merger occurs, a change in accountants is presumed to have occurred as well unless the same auditor audited the pre -merger financial statements of both the registrant and the operating company. The successor aud itor is presumed to be the one who will audit the post -merger financial statements. We note that Synergy Strips Corp. and Oro Capital Corp. had separate auditors. Please amend the Form 8 -K to provide all information required by Item 304 of Regulation S -K.
Mark Suponitsky Synergy Strips Corp. May 12, 2014 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the co mpany and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact me at 202 -551-3394 if you have questions regar ding these comments and related matters.
Sincerely,
/s/ Steve Lo
Show Raw Text
May 12, 2014 Via E-mail Mark Suponitsky Chief Executive Officer Synergy Strips Corp. 2105 Burton Branch Road Algood, TN 38506 Re: Synergy Strips Corp. Form 8 -K Filed May 7 , 2014 File No. 000-55098 Dear Mr. Suponitsky : We have reviewed your filing an d 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 this letter within five business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstanc es or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 8 -K Filed on May 7 , 2014 Change in Accountant 1. When a reverse merger occurs, a change in accountants is presumed to have occurred as well unless the same auditor audited the pre -merger financial statements of both the registrant and the operating company. The successor aud itor is presumed to be the one who will audit the post -merger financial statements. We note that Synergy Strips Corp. and Oro Capital Corp. had separate auditors. Please amend the Form 8 -K to provide all information required by Item 304 of Regulation S -K. Mark Suponitsky Synergy Strips Corp. May 12, 2014 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the co mpany and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please contact me at 202 -551-3394 if you have questions regar ding these comments and related matters. Sincerely, /s/ Steve Lo Steve Lo Staff Accountant