SEC Comment Letter for Onar Holding Corp (ONAR) (CIK 0001682265) (ONAR) — May 18, 2017
Onar Holding Corp (ONAR) (CIK 0001682265)
Date: May 18, 2017 · CIK: 0001682265 · Accession: 0000000000-17-017555
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Mail Stop 4631 May 18 , 2017 Via E -Mail Michael Chavez President Reliant Holdings, Inc. 12343 Hymeadow Drive, Suite 3 -A Austin, Texas 78750 Re: Reliant Holdings, Inc. Amendment No. 4 to Registration Statement on Form S-1 Filed May 4 , 2017 File No. 333 -214274 Dear Mr. Chavez : We have reviewed your amended registration statement and have the following comment s. Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewi ng any amendment to your registration statement and the information you provide in response to this comment , we may have additional comments. General 1. Please note the updating requirements of Rule 8 -08 of Regulation S -X. Liquidity and Capital Resources , page 42 2. We note your receivable of $10k associated with the construction of the personal swimming pool of Michael Chavez, CEO. Please tell us whether you have collected this receivable from Mr. Chavez. If not, please tell us how you concluded that cur rent classification was appropriate and the receivable was fully collectible. 3. We note you had working capital of $45,982 as of December 31, 2015 and $42,309 as of September 30, 2016. We further note that you had a working capital deficit of $12,309 as of December 31, 2016. However, your disclosure regarding the reasons for the change in working capital is identical to your prior disclosure when you reported working capital. Please advise. Michael Chavez Reliant Holdings, Inc. May 18 , 2017 Page 2 4. Given your negative working capital and cash flows from opera ting activities as of December 31, 2016, please disclose cash requirements for the next 12 months and the source of such funds. Refer to Section 501.13.a of the Financial Reporting Codification for guidance. You may contact Tracey McKoy (Staff Accountant) at 202-551-3772 or Terence O’Brien (Accounting Branch Chief ) at 202-551-3355 if you have questions regarding the financial statements and related matters. Please contact Frank Pigott (Staff Attorney) at 202-551-3570 or me at 202-551-3729 with any other questions. Sincerely, /s/ Craig S livka, for Pamela Long Assistant Director Office of Manufacturing and Construction cc: David M. Loev The Loev Law Firm, PC