SEC Comment Letter 0000000000-23-001109 to Yum China Holdings, Inc. (YUMC)
Yum China Holdings, Inc.
Date: Feb. 2, 2023 · CIK: 0001673358 · Accession: 0000000000-23-001109
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo February 2, 2023 Joey Wat Chief Executive Officer Yum China Holdings, Inc. 7100 Corporate Drive Plano, Texas 75024 Re:Yum China Holdings, Inc. Form 10-K for the Year Ended December 31, 2021 Correspondence Filed January 3, 2023 File No. 1-37762 Dear Joey Wat: We have reviewed your January 3, 2023 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 16, 2022 letter. Correspondence Filed January 3, 2023 Item 1A. Risk Factors, page 9 1.We note your response to comment 10. Revise to state whether you believe that you are compliant with the regulations or policies that have been issued by the CAC to date, notwithstanding the various uncertainties you disclose. In this regard, we are not aware of any regulatory process in which you are expected to be identified as a "critical information infrastructure operator" before ensuring compliance with the Revised Cybersecurity Review Measures.
FirstName LastNameJoey Wat Comapany NameYum China Holdings, Inc. February 2, 2023 Page 2 FirstName LastName Joey Wat Yum China Holdings, Inc. February 2, 2023 Page 2 Please contact Taylor Beech at 202-551-4515 or Mara Ransom at 202-551-3264 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Lindsey Smith, Esq.
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United States securities and exchange commission logo
February 2, 2023
Joey Wat
Chief Executive Officer
Yum China Holdings, Inc.
7100 Corporate Drive
Plano, Texas 75024
Re:Yum China Holdings, Inc.
Form 10-K for the Year Ended December 31, 2021
Correspondence Filed January 3, 2023
File No. 1-37762
Dear Joey Wat:
We have reviewed your January 3, 2023 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
December 16, 2022 letter.
Correspondence Filed January 3, 2023
Item 1A. Risk Factors, page 9
1.We note your response to comment 10. Revise to state whether you believe that you are
compliant with the regulations or policies that have been issued by the CAC to date,
notwithstanding the various uncertainties you disclose. In this regard, we are not aware of
any regulatory process in which you are expected to be identified as a "critical information
infrastructure operator" before ensuring compliance with the Revised Cybersecurity
Review Measures.
FirstName LastNameJoey Wat
Comapany NameYum China Holdings, Inc.
February 2, 2023 Page 2
FirstName LastName
Joey Wat
Yum China Holdings, Inc.
February 2, 2023
Page 2
Please contact Taylor Beech at 202-551-4515 or Mara Ransom at 202-551-3264 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Lindsey Smith, Esq.