SEC Comment Letter 0000000000-23-013503 to Futu Holdings Ltd (FUTU) (CIK 0001754581) (FUTU)
Futu Holdings Ltd (FUTU) (CIK 0001754581)
Date: Dec. 12, 2023 · CIK: 0001754581 · Accession: 0000000000-23-013503
AI Filing Summary & Sentiment
File numbers found in text: 001-38820
Letter
United States securities and exchange commission logo December 12, 2023 Arthur Yu Chen Chief Financial Officer Futu Holdings Ltd 11/F, Bangkok Bank Building No. 18 Bonham Strand W, Sheung Wan Hong Kong S.A.R., People’s Republic of China Re:Futu Holdings Ltd Form 20-F for Fiscal Year Ended December 31, 2022 File No. 001-38820 Dear Arthur Yu Chen: We have reviewed your September 28, 2023 response to our comment letter and have the following comments. 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. Unless we note otherwise, any references to prior comments are to comments in our September 18, 2023 letter. Form 20-F for Fiscal Year Ended December 31, 2022 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 222 1.We note your response to prior comment 1 that your subsidiaries in the United States, Singapore, Australia, Japan, Hong Kong, and mainland China are wholly owned and that you are the primary beneficiary of the VIEs and their subsidiaries. Please supplementally clarify for us who holds ownership interests in the VIEs and their subsidiaries. 2.We note your response to prior comment 2 that you conducted inquiries and collected questionnaires from the members of the boards of directors and that nothing has come to your attention suggesting that any Director is an official of the Chinese Communist Party. Please tell us in more detail how you considered the profile of Mr. Shan Lu and particularly his role with the China United Network Communications Group Co., Ltd. Please also tell us how you considered whether Mr. Lu has any current or prior memberships on, or affiliations with, committees of the Chinese Communist Party that are
FirstName LastNameArthur Yu Chen Comapany NameFutu Holdings Ltd December 12, 2023 Page 2 FirstName LastName Arthur Yu Chen Futu Holdings Ltd December 12, 2023 Page 2 not addressed in his biography on page 184 of your Form 20-F and whether he is a member of the Chinese Communist Party.
Please contact Jennifer Gowetski at 202-551-3401 or Andrew Mew at 202-551-3377 with any other questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Will Cai
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United States securities and exchange commission logo
December 12, 2023
Arthur Yu Chen
Chief Financial Officer
Futu Holdings Ltd
11/F, Bangkok Bank Building
No. 18 Bonham Strand W, Sheung Wan
Hong Kong S.A.R., People’s Republic of China
Re:Futu Holdings Ltd
Form 20-F for Fiscal Year Ended December 31, 2022
File No. 001-38820
Dear Arthur Yu Chen:
We have reviewed your September 28, 2023 response to our comment letter and have the
following comments.
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. Unless
we note otherwise, any references to prior comments are to comments in our September 18,
2023 letter.
Form 20-F for Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 222
1.We note your response to prior comment 1 that your subsidiaries in the United States,
Singapore, Australia, Japan, Hong Kong, and mainland China are wholly owned and that
you are the primary beneficiary of the VIEs and their subsidiaries. Please supplementally
clarify for us who holds ownership interests in the VIEs and their subsidiaries.
2.We note your response to prior comment 2 that you conducted inquiries and collected
questionnaires from the members of the boards of directors and that nothing has come to
your attention suggesting that any Director is an official of the Chinese Communist
Party. Please tell us in more detail how you considered the profile of Mr. Shan Lu and
particularly his role with the China United Network Communications Group Co.,
Ltd. Please also tell us how you considered whether Mr. Lu has any current or prior
memberships on, or affiliations with, committees of the Chinese Communist Party that are
FirstName LastNameArthur Yu Chen
Comapany NameFutu Holdings Ltd
December 12, 2023 Page 2
FirstName LastName
Arthur Yu Chen
Futu Holdings Ltd
December 12, 2023
Page 2
not addressed in his biography on page 184 of your Form 20-F and whether he is a
member of the Chinese Communist Party.
Please contact Jennifer Gowetski at 202-551-3401 or Andrew Mew at 202-551-3377 with
any other questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Will Cai