SEC Company Response from Yiren Digital (YRD) — Nov 16, 2015
Yiren Digital Ltd.
Date: Nov. 16, 2015 · CIK: 0001631761 · Accession: 0001193125-15-378457
AI Filing Summary & Sentiment
Letter
Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: Yirendai Ltd. (CIK No. 0001631761) Registration Statement on Form F-1
Dear Mr. King, Mr. Lin, Mr. Pande and Mr. Phippen:
On behalf of our client, Yirendai Ltd., a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), we are filing herewith the Company’s Registration Statement on Form F-1 (the “Registration Statement”) via EDGAR with the Securities and Exchange Commission (the “Commission”). To facilitate your review, we have separately delivered to you today five courtesy copies of the Registration Statement (without exhibits), marked to show changes to the draft Registration Statement confidentially submitted to the Commission on August 7, 2015.
In addition, the Company is supplementally providing (under a separate cover letter) a legal opinion that it obtained from its PRC legal counsel in response to the Staff’s comments raised during the Company’s telephone discussion with the Staff on November 5, 2015.
In accordance with the Jumpstart Our Business Startups Act, the Company plans to file an amendment to the Registration Statement containing the estimated price range and offering size and launch the road show 21 days after the date hereof.
Securities and Exchange Commission
November 16, 2015
Page
If you have any questions regarding the Registration Statement, please contact the undersigned by phone at +852-3740-4863 or via e-mail at julie.gao@skadden.com. Questions relating to accounting and auditing matters of the Company may also be directed to Elsie Zhou, partner at Deloitte Touche Tohmatsu Certified Public Accountants LLP, by phone at +86 10 8520-7142 or via email at ezhou@deloitte.com.cn.
Very truly yours,
/s/ Z. Julie Gao
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SEC Letter
PARTNERS
JOHN ADEBIYI ¿
CHRISTOPHER W. BETTS
WILL H. CAI ^
EDWARD H.P. LAM ¿*
HAIPING LI *
RORY MCALPINE ¿
CLIVE W. ROUGH ¿
JONATHAN B. STONE *
ALEC P. TRACY *
^ (ALSO ADMITTED IN CALIFORNIA)
¿ (ALSO ADMITTED IN
ENGLAND & WALES)
* (ALSO ADMITTED IN NEW
YORK)
REGISTERED FOREIGN LAWYERS
Z. JULIE GAO (CALIFORNIA)
BRADLEY A. KLEIN (ILLINOIS)
GREGORY G.H. MIAO (NEW YORK)
ALAN G. SCHIFFMAN (NEW YORK)
SKADDEN, ARPS, SLATE, MEAGHER & FLOM
42/F, EDINBURGH TOWER, THE LANDMARK
15 QUEEN’S ROAD CENTRAL, HONG KONG
TEL: (852) 3740-4700
FAX: (852)
3740-4727
www.skadden.com
AFFILIATE OFFICES
-----------
BOSTON
CHICAGO
HOUSTON
LOS ANGELES
NEW YORK
PALO ALTO
WASHINGTON, D.C.
WILMINGTON
-----------
BEIJING
BRUSSELS
FRANKFURT
LONDON
MOSCOW
MUNICH
PARIS
SÃO PAULO
SEOUL
SHANGHAI
SINGAPORE
SYDNEY
TOKYO
TORONTO
November 16, 2015
Dietrich King, Assistant Director
David Lin, Staff Attorney
Amit Pande, Accounting Branch Chief
Benjamin Phippen, Staff Accountant
Division of Corporation
Finance
Securities and Exchange Commission
100 F Street,
N.E.
Washington, D.C. 20549
RE:
Yirendai Ltd. (CIK No. 0001631761)
Registration Statement on Form
F-1
Dear Mr. King, Mr. Lin, Mr. Pande and Mr. Phippen:
On behalf of our client, Yirendai Ltd., a foreign private issuer organized under the laws of the Cayman Islands (the
“Company”), we are filing herewith the Company’s Registration Statement on Form F-1 (the “Registration Statement”) via EDGAR with the Securities and Exchange Commission (the “Commission”). To
facilitate your review, we have separately delivered to you today five courtesy copies of the Registration Statement (without exhibits), marked to show changes to the draft Registration Statement confidentially submitted to the Commission on August
7, 2015.
In addition, the Company is supplementally providing (under a separate cover letter) a legal opinion that it obtained from its
PRC legal counsel in response to the Staff’s comments raised during the Company’s telephone discussion with the Staff on November 5, 2015.
In accordance with the Jumpstart Our Business Startups Act, the Company plans to file an amendment to the Registration Statement containing
the estimated price range and offering size and launch the road show 21 days after the date hereof.
Securities and Exchange Commission
November 16, 2015
Page
2
If you have any questions regarding the Registration Statement, please contact the
undersigned by phone at +852-3740-4863 or via e-mail at julie.gao@skadden.com. Questions relating to accounting and auditing matters of the Company may also be directed to Elsie Zhou, partner at Deloitte Touche Tohmatsu Certified Public Accountants
LLP, by phone at +86 10 8520-7142 or via email at ezhou@deloitte.com.cn.
Very truly yours,
/s/ Z. Julie Gao
Z. Julie Gao
Enclosures
cc:
Ning Tang, Executive Chairman, Yirendai Ltd.
Yu Cong, Chief Financial Officer, Yirendai Ltd.
Elsie Zhou, Deloitte Touche Tohmatsu Certified Public Accountants LLP
Chris Lin, Esq., Simpson Thacher & Bartlett LLP