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SEC Comment Letter 0000000000-24-006866 to Akso Health Group (AHG)

Akso Health Group
Date: June 14, 2024 · CIK: 0001702318 · Accession: 0000000000-24-006866

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File numbers found in text: 001-38245

Date
June 14, 2024
Author
Linda Wang
Form
UPLOAD
Company
Akso Health Group

Letter

United States securities and exchange commission logo June 14, 2024 Linda Wang Chief Executive Officer Akso Health Group Room 8201-4-4(A), 2nd Floor, Qiantongyuan Building No. 44, Moscow Road , Qianwan Bonded Port Area Qingdao Pilot Free Trade Zone, China (Shandong) Re:Akso Health Group Form 20-F for the Fiscal Year Ended March 31, 2023 Response Dated May 7, 2024 File No. 001-38245 Dear Linda Wang: We have reviewed your May 7, 2024 response to our comment letter and have the following comment(s). Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our March 19, 2024 letter. Correspondence filed May 7, 2024 Item 3: Key Information, page 1 1.We note your revisions pursuant to comment 1, your proposed revised disclosure and reissue in part. Please disclose, as you do elsewhere, that the contracts relating to the former variable interest entities have not been tested in court. Please also disclose if the former variable interest entity structure was used to provide investors with exposure to foreign investment in China-based companies where Chinese law prohibits direct foreign investment in the operating companies. 2.We note your revisions pursuant to comment 7, your proposed revised disclosure and reissue in part. Please depict more clearly how the VIEs relate to each other and the company within the diagram. In this regard, please also identify the person or entities

FirstName LastNameLinda Wang Comapany NameAkso Health Group June 14, 2024 Page 2 FirstName LastName Linda Wang Akso Health Group June 14, 2024 Page 2 which own the equity in each depicted entity to include the VIEs. Lastly, please also add a footnote or other narrative disclosure to explain the dissolution of your former VIEs. 3.We note your revisions pursuant to comment 9, your proposed revised disclosure and reissue in part. Please revise to specifically discuss the risks and uncertainties regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance notice. Please contact Stephen Kim at 202-551-3291 or Doug Jones at 202-551-3309 if you have questions regarding comments on the financial statements and related matters. Please contact Jenna Hough at 202-551-3063 or Donald Field at 202-551-3680 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Joan Wu

Show Raw Text
United States securities and exchange commission logo
June 14, 2024
Linda Wang
Chief Executive Officer
Akso Health Group
Room 8201-4-4(A), 2nd Floor, Qiantongyuan Building
No. 44, Moscow Road , Qianwan Bonded Port Area
Qingdao Pilot Free Trade Zone, China (Shandong)
Re:Akso Health Group
Form 20-F for the Fiscal Year Ended March 31, 2023
Response Dated May 7, 2024
File No. 001-38245
Dear Linda Wang:
            We have reviewed your May 7, 2024 response to our comment letter and have the
following comment(s).
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our March 19,
2024 letter.
Correspondence filed May 7, 2024
Item 3: Key Information, page 1
1.We note your revisions pursuant to comment 1, your proposed revised disclosure and
reissue in part. Please disclose, as you do elsewhere, that the contracts relating to the
former variable interest entities have not been tested in court. Please also disclose if the
former variable interest entity structure was used to provide investors with exposure to
foreign investment in China-based companies where Chinese law prohibits direct foreign
investment in the operating companies.
2.We note your revisions pursuant to comment 7, your proposed revised disclosure and
reissue in part. Please depict more clearly how the VIEs relate to each other and the
company within the diagram. In this regard, please also identify the person or entities

 FirstName LastNameLinda Wang
 Comapany NameAkso Health Group
 June 14, 2024 Page 2
 FirstName LastName
Linda Wang
Akso Health Group
June 14, 2024
Page 2
which own the equity in each depicted entity to include the VIEs. Lastly, please also add a
footnote or other narrative disclosure to explain the dissolution of your former VIEs.
3.We note your revisions pursuant to comment 9, your proposed revised disclosure and
reissue in part. Please revise to specifically discuss the risks and uncertainties regarding
the enforcement of laws and that rules and regulations in China can change quickly with
little advance notice.
            Please contact Stephen Kim at 202-551-3291 or Doug Jones at 202-551-3309 if you have
questions regarding comments on the financial statements and related matters. Please contact
Jenna Hough at 202-551-3063 or Donald Field at 202-551-3680 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Joan Wu