SEC Comment Letter for TCTM Kids IT Education Inc. (VSA) (CIK 0001592560) (VSA) — Jan 19, 2017
TCTM Kids IT Education Inc. (VSA) (CIK 0001592560)
Date: Jan. 19, 2017 · CIK: 0001592560 · Accession: 0000000000-17-002114
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3720 January 19, 2017 Mr. Shaoyun Han Chief Executive Officer Tarena International, Inc. Suite 10017, Building E Zhongkun Plaza, A18 Bei San Huan West Road Haidian District, Beijing 100098 People’s Republic of China
Re: Tarena International, Inc. Form 20-F for Fiscal Year Ended December 31, 2015 Response dated January 12, 2017 File No. 001 -36363
Dear Mr. Han :
We have reviewed your January 12, 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 . In some of our comments, we may ask you to p rovide 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 Decemb er 28, 2016 letter.
Risk Factors
We may not be able to maintain our high job placement rate for students, which could harm our ability to attract student enrollments, page 6
1. We note your response to our comment 1 describing your methodology for calcul ating the six -month post -course job placement rates for your students . To provide further context, please disclose the percentage of your students who filled out your initial surveys, the percentage of enrolled students who graduated, and the percentage o f students who are deemed to be “job -seeking” students.
Mr. Shaoyun Han Tarena International, Inc. January 19, 2017 Page 2
Item 5. Operating and Financial Review and Prospects, page 67
2. We note your response to our comment 4 that, as a result of your plan to devote more resources to your management of accounts receivabl e, you believe the delinquency risk for these accounts and additions to your bad debt allowances will not continue to increase. Please disclose the specific resources that you plan to devote in this respect , and explain how these resources will lessen the delinquency risk .
You may contact Charles Eastman , Senior Staff Accountant at (202) 551 -3794 or Terry French , Accountant Branch Chief at (202) 551 -3828 if you have questions regarding comments on the financial statements and related matters. Please contact Joshua Shainess at (202) 551 - 7951 , 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 January 19, 2017 Mr. Shaoyun Han Chief Executive Officer Tarena International, Inc. Suite 10017, Building E Zhongkun Plaza, A18 Bei San Huan West Road Haidian District, Beijing 100098 People’s Republic of China Re: Tarena International, Inc. Form 20-F for Fiscal Year Ended December 31, 2015 Response dated January 12, 2017 File No. 001 -36363 Dear Mr. Han : We have reviewed your January 12, 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 . In some of our comments, we may ask you to p rovide 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 Decemb er 28, 2016 letter. Risk Factors We may not be able to maintain our high job placement rate for students, which could harm our ability to attract student enrollments, page 6 1. We note your response to our comment 1 describing your methodology for calcul ating the six -month post -course job placement rates for your students . To provide further context, please disclose the percentage of your students who filled out your initial surveys, the percentage of enrolled students who graduated, and the percentage o f students who are deemed to be “job -seeking” students. Mr. Shaoyun Han Tarena International, Inc. January 19, 2017 Page 2 Item 5. Operating and Financial Review and Prospects, page 67 2. We note your response to our comment 4 that, as a result of your plan to devote more resources to your management of accounts receivabl e, you believe the delinquency risk for these accounts and additions to your bad debt allowances will not continue to increase. Please disclose the specific resources that you plan to devote in this respect , and explain how these resources will lessen the delinquency risk . You may contact Charles Eastman , Senior Staff Accountant at (202) 551 -3794 or Terry French , Accountant Branch Chief at (202) 551 -3828 if you have questions regarding comments on the financial statements and related matters. Please contact Joshua Shainess at (202) 551 - 7951 , 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