SEC Comment Letter for Global Wholehealth Partners Corp (CIK 0001598308) — Apr 1, 2020
Global Wholehealth Partners Corp (CIK 0001598308)
Date: April 1, 2020 · CIK: 0001598308 · Accession: 0000000000-20-002814
AI Filing Summary & Sentiment
File numbers found in text: 000-56035
Letter
April 1, 2020 Charles Strongo Chief Executive Officer and Chairman Global Wholehealth Partners Corporation 2227 Avenida Oliva San Clemente, California 92673 Re:Global Wholehealth Partners Corporation Amendment No. 2 to Registration Statement on Form 10-12G Filed March 20, 2020 File No. 000-56035 Dear Mr. Strongo: We have reviewed your filing and 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 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. Amendment No. 2 to Registration Statement on Form 10-12G Item 13. Financial Statements and Supplementary Data, page 31 1.We partially reissue comment eight. Please revise your disclosures under management's discussion and analysis at page 19 to include a comparative analysis and discussion of your financial condition and results of operations for the most recent interim periods presented in your Form 10 to comply with Item 303(b) of Regulation S-X.
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.
FirstName LastNameCharles Strongo Comapany NameGlobal Wholehealth Partners Corporation April 1, 2020 Page 2 FirstName LastName Charles Strongo Global Wholehealth Partners Corporation April 1, 2020 Page 2 You may contact Brian McAllister, Staff Accountant, at 202-551-3341 or Craig Arakawa, Accounting Branch Chief, at 202-551-3650 if you have questions regarding comments on the financial statements and related matters. Please contact Irene Barberena-Meissner, Staff Attorney, at 202-551-6548 or Suzanne Hayes, Office Chief, at 202-551-3675 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Trisha Bollman
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April 1, 2020
Charles Strongo
Chief Executive Officer and Chairman
Global Wholehealth Partners Corporation
2227 Avenida Oliva
San Clemente, California 92673
Re:Global Wholehealth Partners Corporation
Amendment No. 2 to Registration Statement on Form 10-12G
Filed March 20, 2020
File No. 000-56035
Dear Mr. Strongo:
We have reviewed your filing and 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 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.
Amendment No. 2 to Registration Statement on Form 10-12G
Item 13. Financial Statements and Supplementary Data, page 31
1.We partially reissue comment eight. Please revise your disclosures under management's
discussion and analysis at page 19 to include a comparative analysis and discussion of
your financial condition and results of operations for the most recent interim periods
presented in your Form 10 to comply with Item 303(b) of Regulation S-X.
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.
FirstName LastNameCharles Strongo
Comapany NameGlobal Wholehealth Partners Corporation
April 1, 2020 Page 2
FirstName LastName
Charles Strongo
Global Wholehealth Partners Corporation
April 1, 2020
Page 2
You may contact Brian McAllister, Staff Accountant, at 202-551-3341 or Craig Arakawa,
Accounting Branch Chief, at 202-551-3650 if you have questions regarding comments on the
financial statements and related matters. Please contact Irene Barberena-Meissner, Staff
Attorney, at 202-551-6548 or Suzanne Hayes, Office Chief, at 202-551-3675 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Trisha Bollman