SEC Comment Letter 0000000000-23-007831 to Aesthetic Medical International Holdings Group Ltd (PAIYY)
Aesthetic Medical International Holdings Group Ltd
Date: July 21, 2023 · CIK: 0001757143 · Accession: 0000000000-23-007831
AI Filing Summary & Sentiment
File numbers found in text: 001-39088
Letter
United States securities and exchange commission logo July 21, 2023 Zhou Pengwu Chief Executive Officer Aesthetic Medical International Holdings Group Ltd 1122 Nanshan Boulevard Nanshan District, Shenzhen Guangdong Province, China 518052 Re:Aesthetic Medical International Holdings Group Ltd Form 20-F for the Year Ended December 31, 2022 Filed April 21, 2023 File No. 001-39088 Dear Zhou Pengwu: We have limited our review of your filing to the submission and/or disclosures as required by Item 16I of Form 20-F and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. After reviewing your response to this comment, we may have additional comments. Form 20-F for the Year Ended December 31, 2022 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 143 1.We note that during your fiscal year 2022 you were identified by the Commission pursuant to Section 104(i)(2)(A) of the Sarbanes-Oxley Act of 2002 (15 U.S.C. 7214(i)(2)(A)) as having retained, for the preparation of the audit report on your financial statements included in the Form 20-F, a registered public accounting firm that has a branch or office that is located in a foreign jurisdiction and that the Public Company Accounting Oversight Board had determined it is unable to inspect or investigate completely because of a position taken by an authority in the foreign jurisdiction. Please provide the documentation required by Item 16I(a) of Form 20-F or tell us why you are not required to do so. Additionally, please amend your Form 20-F to provide the disclosures required under Item 16I(b) of Form 20-F. Refer to the Staff Statement on the Holding Foreign Companies Accountable Act and the Consolidated Appropriations Act, 2023, available on our website at https://www.sec.gov/corpfin/announcement/statement-
FirstName LastNameZhou Pengwu Comapany NameAesthetic Medical International Holdings Group Ltd July 21, 2023 Page 2 FirstName LastName Zhou Pengwu Aesthetic Medical International Holdings Group Ltd July 21, 2023 Page 2 hfcaa-040623. 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. Please contact Kyle Wiley at (202) 344-5791 or Jennifer Thompson at (202) 551-3737 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Yu Wang
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United States securities and exchange commission logo
July 21, 2023
Zhou Pengwu
Chief Executive Officer
Aesthetic Medical International Holdings Group Ltd
1122 Nanshan Boulevard
Nanshan District, Shenzhen
Guangdong Province, China 518052
Re:Aesthetic Medical International Holdings Group Ltd
Form 20-F for the Year Ended December 31, 2022
Filed April 21, 2023
File No. 001-39088
Dear Zhou Pengwu:
We have limited our review of your filing to the submission and/or disclosures as
required by Item 16I of Form 20-F and have the following comment. In our comment, we may
ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.
After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 143
1.We note that during your fiscal year 2022 you were identified by the Commission
pursuant to Section 104(i)(2)(A) of the Sarbanes-Oxley Act of 2002 (15 U.S.C.
7214(i)(2)(A)) as having retained, for the preparation of the audit report on your financial
statements included in the Form 20-F, a registered public accounting firm that has a
branch or office that is located in a foreign jurisdiction and that the Public Company
Accounting Oversight Board had determined it is unable to inspect or investigate
completely because of a position taken by an authority in the foreign jurisdiction. Please
provide the documentation required by Item 16I(a) of Form 20-F or tell us why you are
not required to do so. Additionally, please amend your Form 20-F to provide the
disclosures required under Item 16I(b) of Form 20-F. Refer to the Staff Statement on the
Holding Foreign Companies Accountable Act and the Consolidated Appropriations Act,
2023, available on our website at https://www.sec.gov/corpfin/announcement/statement-
FirstName LastNameZhou Pengwu
Comapany NameAesthetic Medical International Holdings Group Ltd
July 21, 2023 Page 2
FirstName LastName
Zhou Pengwu
Aesthetic Medical International Holdings Group Ltd
July 21, 2023
Page 2
hfcaa-040623.
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.
Please contact Kyle Wiley at (202) 344-5791 or Jennifer Thompson at (202) 551-3737
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Yu Wang