SEC Comment Letter for Greenland Technologies Holding Corp. (GTEC) (CIK 0001735041) (GTEC) — Sep 3, 2019
Greenland Technologies Holding Corp. (GTEC) (CIK 0001735041)
Date: Sept. 3, 2019 · CIK: 0001735041 · Accession: 0000000000-19-013090
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September 3, 2019 Yanming Liu Chief Executive Officer Greenland Acquisition Corporation Suite 906, Tower W1, Oriental Plaza, No. 1 East Chang'an Street Dongcheng District Beijing, People's Republic of China Re:Greenland Acquisition Corporation Revised Preliminary Proxy Statement on Schedule 14A Filed August 21, 2019 File No. 1-38605 Dear Mr. Liu: We have reviewed your filing and have the following comments. In some of our comments we may ask you to provide us information so that we may better understand your disclosure. Please respond to these comments within 10 business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe that 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. Revised Preliminary Proxy Statement on Schedule 14A filed August 21, 2019 Financial Statements of Zhongchai Holding (Hong Kong) Limited for the Period Ended June 30, Note 7 - Property, Plant and Equipment, page F-53 1.Please revise your presentation to ensure the total amounts of property, plant and equipment, net are properly displayed within the table on page F-53. Financial Statements of Zhongchai Holding (Hong Kong) Limited for the Year Ended December 31, 2018 Note 25 - Subsequent Events, page F-91 2.We have reviewed your response to prior comment 18. We note that you have now
FirstName LastNameYanming Liu Comapany NameGreenland Acquisition Corporation September 3, 2019 Page 2 FirstName LastName Yanming Liu Greenland Acquisition Corporation September 3, 2019 Page 2 disclosed the actual date through which subsequent events have been evaluated. Please revise your disclosure here and on page F-60 to disclose also whether the date through which subsequent events have been evaluated is the date the financial statements were issued or the date the financial statements were available to be issued. Refer to ASC 855- 10-50-1. 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. You may contact Jeffrey R. Gordon, Staff Accountant, at (202) 551-3866 or W. John Cash, Accounting Branch Chief, at (202) 551-3768 if you have questions regarding comments on the financial statements and related matters. Please contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 or Jay E. Ingram, Legal Branch Chief, at (202) 551-3397 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing and Construction
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September 3, 2019
Yanming Liu
Chief Executive Officer
Greenland Acquisition Corporation
Suite 906, Tower W1, Oriental Plaza, No. 1 East
Chang'an Street
Dongcheng District
Beijing, People's Republic of China
Re:Greenland Acquisition Corporation
Revised Preliminary Proxy Statement on Schedule 14A
Filed August 21, 2019
File No. 1-38605
Dear Mr. Liu:
We have reviewed your filing and have the following comments. In some of our
comments we may ask you to provide us information so that we may better understand your
disclosure.
Please respond to these comments within 10 business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe that
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.
Revised Preliminary Proxy Statement on Schedule 14A filed August 21, 2019
Financial Statements of Zhongchai Holding (Hong Kong) Limited for the Period Ended June 30,
2019
Note 7 - Property, Plant and Equipment, page F-53
1.Please revise your presentation to ensure the total amounts of property, plant and
equipment, net are properly displayed within the table on page F-53.
Financial Statements of Zhongchai Holding (Hong Kong) Limited for the Year Ended December
31, 2018
Note 25 - Subsequent Events, page F-91
2.We have reviewed your response to prior comment 18. We note that you have now
FirstName LastNameYanming Liu
Comapany NameGreenland Acquisition Corporation
September 3, 2019 Page 2
FirstName LastName
Yanming Liu
Greenland Acquisition Corporation
September 3, 2019
Page 2
disclosed the actual date through which subsequent events have been evaluated. Please
revise your disclosure here and on page F-60 to disclose also whether the date through
which subsequent events have been evaluated is the date the financial statements were
issued or the date the financial statements were available to be issued. Refer to ASC 855-
10-50-1.
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.
You may contact Jeffrey R. Gordon, Staff Accountant, at (202) 551-3866 or W. John
Cash, Accounting Branch Chief, at (202) 551-3768 if you have questions regarding comments on
the financial statements and related matters. Please contact Edward M. Kelly, Senior Counsel, at
(202) 551-3728 or Jay E. Ingram, Legal Branch Chief, at (202) 551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction