SEC Comment Letter 0000000000-23-009221 to Yum China Holdings, Inc. (YUMC)
Yum China Holdings, Inc.
Date: Aug. 22, 2023 · CIK: 0001673358 · Accession: 0000000000-23-009221
AI Filing Summary & Sentiment
File numbers found in text: 001-37762
Letter
United States securities and exchange commission logo August 22, 2023 Andy Yeung Chief Financial Officer Yum China Holdings, Inc. 101 East Park Boulevard, Suite 805 Plano, Texas 75074 Re:Yum China Holdings, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 File No. 001-37762 Dear Andy Yeung: We have limited our review of your filing to the submission and/or disclosures as required by Item 9C of Form 10-K 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. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2022 Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 130 1.We note that you performed due diligence in connection with your required submission under paragraph (a) of Item 9C of Form 10-K. Your inquiry appears to have included a review of public filings, including your material contracts, and a representation concerning your board of directors. Please tell us whether you reviewed any additional materials as part of your due diligence inquiry and explain your due diligence supporting the representation concerning your board of directors. In addition, please tell us whether you have also relied upon legal opinions or third party certifications such as affidavits as the basis for your submission. 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 LastNameAndy Yeung Comapany NameYum China Holdings, Inc. August 22, 2023 Page 2 FirstName LastName Andy Yeung Yum China Holdings, Inc. August 22, 2023 Page 2 Please contact Christopher Dunham at 202-551-3783 or Jennifer Gowetski at 202-551- 3401 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Lindsey Smith
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United States securities and exchange commission logo
August 22, 2023
Andy Yeung
Chief Financial Officer
Yum China Holdings, Inc.
101 East Park Boulevard, Suite 805
Plano, Texas 75074
Re:Yum China Holdings, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
File No. 001-37762
Dear Andy Yeung:
We have limited our review of your filing to the submission and/or disclosures as
required by Item 9C of Form 10-K 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.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 130
1.We note that you performed due diligence in connection with your required submission
under paragraph (a) of Item 9C of Form 10-K. Your inquiry appears to have included a
review of public filings, including your material contracts, and a representation
concerning your board of directors. Please tell us whether you reviewed any additional
materials as part of your due diligence inquiry and explain your due diligence supporting
the representation concerning your board of directors. In addition, please tell us whether
you have also relied upon legal opinions or third party certifications such as affidavits as
the basis for your submission.
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 LastNameAndy Yeung
Comapany NameYum China Holdings, Inc.
August 22, 2023 Page 2
FirstName LastName
Andy Yeung
Yum China Holdings, Inc.
August 22, 2023
Page 2
Please contact Christopher Dunham at 202-551-3783 or Jennifer Gowetski at 202-551-
3401 with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Lindsey Smith