SEC Comment Letter for Qfin Holdings, Inc. (QFIN, QFNHF) (CIK 0001741530) (QFIN) — Nov 16, 2018
Qfin Holdings, Inc. (QFIN, QFNHF) (CIK 0001741530)
Date: Nov. 16, 2018 · CIK: 0001741530 · Accession: 0000000000-18-035616
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-228020
Letter
November 16, 2018 Jun Xu Chief Executive Officer and Director 360 Finance, Inc. China Diamond Exchange Center, Building B No. 555 Pudian Road, No. 1701 Century Avenue Pudong New Area, Shanghai 200122 People's Republic of China Re:360 Finance, Inc. Amendment No. 1 to Registration Statement on Form F-1 Filed November 6, 2018 File No. 333-228020 Dear Mr. Xu: We have reviewed your amended 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 amending your registration statement and providing the requested information. 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 response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Amendment No. 1 to Form F-1 Notes to the Unaudited Condensed Combined and Consolidated Financial Statements... 9. Ordinary Shares and Preferred Shares, page F-60 1.We note your disclosures on pages F-61 and F-62 regarding the Series A and A+ convertible redeemable preferred shares. Please enhance your disclosures to describe with more detail how you determined the accounting treatment and the amount of the deemed dividend that you recognized as a result of the September 2018 reorganization.
FirstName LastNameJun Xu Comapany Name360 Finance, Inc. November 16, 2018 Page 2 FirstName LastName Jun Xu 360 Finance, Inc. November 16, 2018 Page 2 You may contact Lory Empie, Staff Accountant, at (202) 551-3714 or Cara Lubit, Staff Accountant, at (202) 551-5909 if you have questions regarding comments on the financial statements and related matters. Please contact Christopher Dunham, Staff Attorney, at (202) 551- 3783 or Michael Clampitt, Senior Counsel, at (202) 551-3434 with any other questions. Sincerely, Division of Corporation Finance Office of Financial Services cc: Will H. Cai, Esq.
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November 16, 2018
Jun Xu
Chief Executive Officer and Director
360 Finance, Inc.
China Diamond Exchange Center, Building B
No. 555 Pudian Road, No. 1701 Century Avenue
Pudong New Area, Shanghai 200122
People's Republic of China
Re:360 Finance, Inc.
Amendment No. 1 to
Registration Statement on Form F-1
Filed November 6, 2018
File No. 333-228020
Dear Mr. Xu:
We have reviewed your amended 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 amending your registration statement and providing the
requested information. 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
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 1 to Form F-1
Notes to the Unaudited Condensed Combined and Consolidated Financial Statements...
9. Ordinary Shares and Preferred Shares, page F-60
1.We note your disclosures on pages F-61 and F-62 regarding the Series A and A+
convertible redeemable preferred shares. Please enhance your disclosures to describe with
more detail how you determined the accounting treatment and the amount of the deemed
dividend that you recognized as a result of the September 2018 reorganization.
FirstName LastNameJun Xu
Comapany Name360 Finance, Inc.
November 16, 2018 Page 2
FirstName LastName
Jun Xu
360 Finance, Inc.
November 16, 2018
Page 2
You may contact Lory Empie, Staff Accountant, at (202) 551-3714 or Cara Lubit, Staff
Accountant, at (202) 551-5909 if you have questions regarding comments on the financial
statements and related matters. Please contact Christopher Dunham, Staff Attorney, at (202) 551-
3783 or Michael Clampitt, Senior Counsel, at (202) 551-3434 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services
cc: Will H. Cai, Esq.