SEC Comment Letter for Nisun International Enterprise Development Group Co., Ltd (NISN) (CIK 0001603993) (AIOS) — Jan 9, 2018
Nisun International Enterprise Development Group Co., Ltd (NISN) (CIK 0001603993)
Date: Jan. 9, 2018 · CIK: 0001603993 · Accession: 0000000000-18-000803
AI Filing Summary & Sentiment
Referenced dates: November 7, 2017
Letter
Mail Stop 4631 January 5, 2018 Via E -mail Steven Fu Chief Financial Officer Hebron Technology Co., Ltd. No. 936, Jinhai 2rd Road, Konggang New Area Longwan District Wenzhou City, Zhejiang Province People’s Republic of China
Re: Hebron Technology Co., Ltd. Form 20-F for Fiscal Year Ended December 31, 2016 Filed April 11, 2017 Responses Dated December 21, 2017 and December 27, 2017 File No. 1 -37829
Dear Mr. Fu :
We have reviewed your December 21, 2017 and December 27, 2017 response s to our comment letter and have the following comment s. 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 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 comments apply to your facts and circumstances, please tell us why in your response.
After review ing your response to these comments, we may have additional comments.
General
1. With regard to the draft amendment to Form 20 -F, please address the following: Include the complete text for each item that you include in the amended form in accordanc e with Exchange Act Rule 12b -15. Please refer to General Instructions B(b) to Form 20 -F for guidance. Provided the required information for fiscal year 2014 in Item 4. Include Item 5 of Form 20 -F for fiscal year 2014. Expand Notes 13 and 14 to the consoli dated financial statements to include the corresponding information for fiscal year 2014.
Mr. Fu Hebron Technology Co., Ltd. January 5, 2018 Page 2
Item 3. Key Information, page 4 A. Selected Financial Data, page 4
2. As previously requested in comment 1 in our letter dated November 7, 2017, please revise the parenthetical prior to the tabular presentation to remove the reference that the amounts presented are in thousands of U.S. dollars.
13. Major Customers and Suppliers, page F -22
3. We note your response to comment 2 in our letter dated November 7, 2017, inc luding the draft disclosure you intend to include in the amendment to your Form 20 -F. Please address the need to revise the corresponding disclosures provided in your audited footnotes. Please also expand your disclosures to include the amount of revenue s recognized for each customer that exceeds 10% of total revenues for each fiscal year presented in accordance with ASC 280-10-50-42.
You may contact Tracey Houser, Staff Accountant, at (202) 551 -3736, or in her absence, me at (202) 551 -3355, if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Terence O ’Brien
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Mail Stop 4631 January 5, 2018 Via E -mail Steven Fu Chief Financial Officer Hebron Technology Co., Ltd. No. 936, Jinhai 2rd Road, Konggang New Area Longwan District Wenzhou City, Zhejiang Province People’s Republic of China Re: Hebron Technology Co., Ltd. Form 20-F for Fiscal Year Ended December 31, 2016 Filed April 11, 2017 Responses Dated December 21, 2017 and December 27, 2017 File No. 1 -37829 Dear Mr. Fu : We have reviewed your December 21, 2017 and December 27, 2017 response s to our comment letter and have the following comment s. 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 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 comments apply to your facts and circumstances, please tell us why in your response. After review ing your response to these comments, we may have additional comments. General 1. With regard to the draft amendment to Form 20 -F, please address the following: Include the complete text for each item that you include in the amended form in accordanc e with Exchange Act Rule 12b -15. Please refer to General Instructions B(b) to Form 20 -F for guidance. Provided the required information for fiscal year 2014 in Item 4. Include Item 5 of Form 20 -F for fiscal year 2014. Expand Notes 13 and 14 to the consoli dated financial statements to include the corresponding information for fiscal year 2014. Mr. Fu Hebron Technology Co., Ltd. January 5, 2018 Page 2 Item 3. Key Information, page 4 A. Selected Financial Data, page 4 2. As previously requested in comment 1 in our letter dated November 7, 2017, please revise the parenthetical prior to the tabular presentation to remove the reference that the amounts presented are in thousands of U.S. dollars. 13. Major Customers and Suppliers, page F -22 3. We note your response to comment 2 in our letter dated November 7, 2017, inc luding the draft disclosure you intend to include in the amendment to your Form 20 -F. Please address the need to revise the corresponding disclosures provided in your audited footnotes. Please also expand your disclosures to include the amount of revenue s recognized for each customer that exceeds 10% of total revenues for each fiscal year presented in accordance with ASC 280-10-50-42. You may contact Tracey Houser, Staff Accountant, at (202) 551 -3736, or in her absence, me at (202) 551 -3355, if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Terence O ’Brien Terence O’Brien Accounting Branch Chief Office of Manufacturing and Construction