SEC Comment Letter for Clancy Corp (CIK 0001681769) — Aug 29, 2022
Clancy Corp (CIK 0001681769)
Date: Aug. 29, 2022 · CIK: 0001681769 · Accession: 0000000000-22-009359
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File numbers found in text: 333-213698
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United States securities and exchange commission logo
August 29, 2022
Xiangying Meng
President and CEO
Clancy Corp
2nd Floor, BYD, No. 56, Dongsihuan South Road
Chaoyang District, Beijing, China 100023
Re:Clancy Corp
Form 10-K for the Fiscal Year Ended July 31, 2021
Response Dated August 15, 2022
File No. 333-213698
Dear Mr. Meng:
We have reviewed your August 15, 2022 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
August 3, 2022 letter.
Form 10-K for the Fiscal Year Ended July 31, 2021
Report of Independent Registered Public Accounting Firm, page F-2
1.We have reviewed the draft revised audit report provided in response to prior comment
12. As previously requested, your auditor must:
•Refer to related notes and related schedules in the identification of the financial
statements in their opinion paragraph;
•Provide the required explanatory language set forth in AS 3101.18.g related to
internal controls over financial reporting in their basis for opinion paragraphs. See AS
3105.59; and
•Provide critical audit matters information as required by paragraphs AS 3101.15 or
.16.
FirstName LastNameXiangying Meng
Comapany NameClancy Corp
August 29, 2022 Page 2
FirstName LastName
Xiangying Meng
Clancy Corp
August 29, 2022
Page 2
In addition, the opinion paragraph should refer to accounting principles generally accepted
in the United States of America.
2.We note in response to prior comment 13, the draft revised audit report includes a going
concern paragraph. Please note that this paragraph must be preceded by an appropriately
labeled heading such as "Going Concern" and must be presented directly after the Opinion
on the financial statements paragraph. Refer to AU Section 341.03(c) and AS 2415.03(c).
General
3.Please amend your Form 10-K for the Fiscal Year Ended July 31, 2021 to include the
disclosure requested from prior comments one to ten.
You may contact Jeanne Baker at (202) 551-3691 or Terence O'Brien at (202) 551-3355
if you have questions regarding comments on the financial statements and related matters. Please
contact Dillon Hagius at (202) 551-7967 or Celeste Murphy at (202) 551-3257 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Daniel Luciano