SEC Comment Letter for Cango Inc. (CANG) (CIK 0001725123) (CANG) — Jun 1, 2018
Cango Inc. (CANG) (CIK 0001725123)
Date: June 1, 2018 · CIK: 0001725123 · Accession: 0000000000-18-016861
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4561 May 31, 2018 Jiayuan Lin Chief Executive Officer Cango Inc. 10A, Building 3, Youyou Century Plaza 428 South Yanggao Road Pudong New Area, Shanghai 200127 People’s Republic of China
Re: Cango Inc. Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted May 22 , 2018 CIK No. 0001725123
Dear Mr. Lin :
We have reviewed your amended draft registration statement 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 this letter by providing the requested information and either s ubmitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your r esponse.
After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Unless we note otherwise, our references to prior comment s are to comments in our May 18, 2018 letter.
Report of Independent Registered Public Accounting Firm, page F -2
1. Please have your independent registered public accounting firm revise its report to add the related notes as part of the collectively referen ced financial statements within the Opinion Section of the report. We refer you to PCAOB Release No. 2017 -001.
Jiayuan Lin Cango Inc. May 31, 2018 Page 2
Notes to the Consolidated Financial Statements
Note 26. Subsequent Events, page F -54
2. Please update your subsequent events disclosure through the date of issuance of your financial statements. Refer to ASC 855 -10-50.
You may contact Ryan Rohn , Staff Accountant, at (202) 551 -3739 , or Craig Wilson , Senior Assistant Chief Accountant, at (202) 551 -3226 , if you have questions regarding comments on the financial s tatements and related matters. Please contact Jeff Kauten, Attorney -Advisor, at (202) 551 - 3447 , or in his absence, me at (202) 551 -3483 , with any other questions. If you require further assistance, please contact Barbara C. Jacobs , Assistant Director, at (202) 551 -3730.
Sincerely,
/s/ Katherine Wray
Show Raw Text
Mail Stop 4561 May 31, 2018 Jiayuan Lin Chief Executive Officer Cango Inc. 10A, Building 3, Youyou Century Plaza 428 South Yanggao Road Pudong New Area, Shanghai 200127 People’s Republic of China Re: Cango Inc. Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted May 22 , 2018 CIK No. 0001725123 Dear Mr. Lin : We have reviewed your amended draft registration statement 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 this letter by providing the requested information and either s ubmitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your r esponse. After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Unless we note otherwise, our references to prior comment s are to comments in our May 18, 2018 letter. Report of Independent Registered Public Accounting Firm, page F -2 1. Please have your independent registered public accounting firm revise its report to add the related notes as part of the collectively referen ced financial statements within the Opinion Section of the report. We refer you to PCAOB Release No. 2017 -001. Jiayuan Lin Cango Inc. May 31, 2018 Page 2 Notes to the Consolidated Financial Statements Note 26. Subsequent Events, page F -54 2. Please update your subsequent events disclosure through the date of issuance of your financial statements. Refer to ASC 855 -10-50. You may contact Ryan Rohn , Staff Accountant, at (202) 551 -3739 , or Craig Wilson , Senior Assistant Chief Accountant, at (202) 551 -3226 , if you have questions regarding comments on the financial s tatements and related matters. Please contact Jeff Kauten, Attorney -Advisor, at (202) 551 - 3447 , or in his absence, me at (202) 551 -3483 , with any other questions. If you require further assistance, please contact Barbara C. Jacobs , Assistant Director, at (202) 551 -3730. Sincerely, /s/ Katherine Wray Katherine Wray Attorney -Advisor Office of Information Technologies and Services cc: Chris K.H. Lin, Esq. Simpson Thacher & Bartlett LLP