SEC Comment Letter 0000000000-23-011260 to CNFinance Holdings Ltd. (CNF) (CIK 0001733868) (CNF)
CNFinance Holdings Ltd. (CNF) (CIK 0001733868)
Date: Oct. 16, 2023 · CIK: 0001733868 · Accession: 0000000000-23-011260
AI Filing Summary & Sentiment
File numbers found in text: 001-38726
Letter
United States securities and exchange commission logo October 16, 2023 Bin Zhai Chief Executive Officer CNFinance Holdings Ltd. 44/F, Tower G, No. 16 Zhujiang Dong Road Tianhe District, Guangzhou City Guangdong Province 510620 People’s Republic of China Re:CNFinance Holdings Ltd. Form 20-F for Fiscal Year Ended December 31, 2022 Response dated September 13, 2023 File No. 001-38726 Dear Bin Zhai: We have reviewed your filing and have the following comment. 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. Form 20-F for Fiscal Year Ended December 31, 2022 Item 16.I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 138 1.Your response to prior comment 2 indicates that you reviewed the profiles of the directors before concluding that none of your directors or the directors of your consolidated entities are officials of the Chinese Communist Party. Please tell us in more detail how you considered the profile of Mr. Lin Xu and particularly his roles with the National Development and Reform Commission. Please also tell us how you considered whether Mr. Xu has any current or prior memberships on, or affiliations with, committees of the Chinese Communist Party that are not addressed in his biography on page 113 of your Form 20-F and whether he is a member of the Chinese Communist Party.
FirstName LastNameBin Zhai Comapany NameCNFinance Holdings Ltd. October 16, 2023 Page 2 FirstName LastName Bin Zhai CNFinance Holdings Ltd. October 16, 2023 Page 2 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. Contact Jennifer Thompson at 202-551-3737 if you have any questions about comments related to your status as a Commission-Identified Issuer during your most recently completed fiscal year. Please contact Michael Henderson at 202-551-3364 or Marc Thomas at 202-551-3452 if you have questions regarding comments on the financial statements and related matters. Please contact Aisha Adegbuyi at 202-551-8754 or Tonya Aldave at 202-551-3601 with any other questions. Sincerely, Division of Corporation Finance Office of Finance cc: James C. Lin, Esq.
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United States securities and exchange commission logo
October 16, 2023
Bin Zhai
Chief Executive Officer
CNFinance Holdings Ltd.
44/F, Tower G, No. 16 Zhujiang Dong Road
Tianhe District, Guangzhou City
Guangdong Province 510620
People’s Republic of China
Re:CNFinance Holdings Ltd.
Form 20-F for Fiscal Year Ended December 31, 2022
Response dated September 13, 2023
File No. 001-38726
Dear Bin Zhai:
We have reviewed your filing and have the following comment.
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.
Form 20-F for Fiscal Year Ended December 31, 2022
Item 16.I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 138
1.Your response to prior comment 2 indicates that you reviewed the profiles of the directors
before concluding that none of your directors or the directors of your consolidated entities
are officials of the Chinese Communist Party. Please tell us in more detail how you
considered the profile of Mr. Lin Xu and particularly his roles with the National
Development and Reform Commission. Please also tell us how you considered whether
Mr. Xu has any current or prior memberships on, or affiliations with, committees of the
Chinese Communist Party that are not addressed in his biography on page 113 of your
Form 20-F and whether he is a member of the Chinese Communist Party.
FirstName LastNameBin Zhai
Comapany NameCNFinance Holdings Ltd.
October 16, 2023 Page 2
FirstName LastName
Bin Zhai
CNFinance Holdings Ltd.
October 16, 2023
Page 2
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.
Contact Jennifer Thompson at 202-551-3737 if you have any questions about comments
related to your status as a Commission-Identified Issuer during your most recently completed
fiscal year.
Please contact Michael Henderson at 202-551-3364 or Marc Thomas at 202-551-3452 if
you have questions regarding comments on the financial statements and related matters. Please
contact Aisha Adegbuyi at 202-551-8754 or Tonya Aldave at 202-551-3601 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: James C. Lin, Esq.