SEC Comment Letter for MDJM LTD (UOKA, UOKAF) (CIK 0001741534) (UOKAF) — Jul 31, 2018
MDJM LTD (UOKA, UOKAF) (CIK 0001741534)
Date: July 31, 2018 · CIK: 0001741534 · Accession: 0000000000-18-023608
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3233 July 30, 2018 Via E -mail Siping Xu , Chairman and Chief Executive Officer MDJM LTD Suite C -1505, Saidun Center Xikang Road, Heping District, Tianjin People’s Republic of China
Re: MDJM LTD Amendment No. 1 to Draft Registration Statement on Form F -1 Submitted July 11, 2018 CIK No. 0001741534
Dear Mr. Xu :
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 submitting 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 response.
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.
Note 3 – Accounts Receivable, page F -14
1. We note your revised disclosures in response to prior comment 9. Your disclosure indicates that management makes conclusions on whether any balances outstanding at the end of each reporting period will be deemed uncollectible on an individual basis and on an aging trend analysis basis. Please clarify at what stage of delinquency (i.e. what point in the aging) you record a re serve for a delinquent account .
Siping Xu, Chairman and Chief Executive Officer MDJM LTD July 30, 2018 Page 2
2. Given that you have not received any collections on your $559,234 receivable and have only received modest collections on your $443,057 receivable, please tell us in detail why you believe further im pairment of these loans is not required.
You may contact William Demarest at (202)551 -3432 or Kristi Marrone at (202)551 - 3429 if you have questions regarding comments on the financial statements and re lated matters. Please contact Stacie Gorman at (202)5 51-3585 or me at (202)551 -3401 with any other questions.
Sincerely,
/s/ Jennifer Gowetski
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Mail Stop 3233
July 30, 2018
Via E -mail
Siping Xu , Chairman and Chief Executive Officer
MDJM LTD
Suite C -1505, Saidun Center
Xikang Road, Heping District, Tianjin
People’s Republic of China
Re: MDJM LTD
Amendment No. 1 to Draft Registration Statement on Form F -1
Submitted July 11, 2018
CIK No. 0001741534
Dear Mr. Xu :
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 submitting
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 response.
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.
Note 3 – Accounts Receivable, page F -14
1. We note your revised disclosures in response to prior comment 9. Your disclosure
indicates that management makes conclusions on whether any balances outstanding at the
end of each reporting period will be deemed uncollectible on an individual basis and on
an aging trend analysis basis. Please clarify at what stage of delinquency (i.e. what point
in the aging) you record a re serve for a delinquent account .
Siping Xu, Chairman and Chief Executive Officer
MDJM LTD
July 30, 2018
Page 2
2. Given that you have not received any collections on your $559,234 receivable and have
only received modest collections on your $443,057 receivable, please tell us in detail why
you believe further im pairment of these loans is not required.
You may contact William Demarest at (202)551 -3432 or Kristi Marrone at (202)551 -
3429 if you have questions regarding comments on the financial statements and re lated matters.
Please contact Stacie Gorman at (202)5 51-3585 or me at (202)551 -3401 with any other questions.
Sincerely,
/s/ Jennifer Gowetski
Jennifer Gowetski
Senior Counsel
Office of Real Estate and
Commodities
cc: Ying Li, Esq. ( via e -mail)