Correspondence 0001213900-23-047419 from Prestige Wealth Inc. (PWM) (CIK 0001765850) (AURE)
Prestige Wealth Inc. (PWM) (CIK 0001765850)
Date: June 8, 2023 · CIK: 0001765850 · Accession: 0001213900-23-047419
AI Filing Summary & Sentiment
File numbers found in text: 333-267999
Referenced dates: May 30, 2023
Letter
Via EDGAR Division of Corporation Finance Office of Financial Services Re: Prestige Wealth Inc. Amendment No. 4 to Registration Statement on Form F-1 Filed May 12, 2023 File No. 333-267999
Dear Ms. Mateo and Ms. Block:
This letter is in response to the letter dated May 30, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) addressed to Prestige Wealth Inc. (the “Company”, “we”, or “our”). For ease of reference, we have recited the Commission’s comment in this response.
Amendment No. 4 to Registration Statement on Form F-1 filed May 12, 2023
General
1. We note your response to our prior comment 1 and reissue the comment in part. As such, the staff reiterates that the Revised Separateness Test (as defined in your response letter) is not the appropriate analytical framework in this scenario where the staff’s question, in the first instance, is whether PWAI, on the one hand, and the Asset Management Subsidiaries, on the other, are integrated under general Advisers Act principles. Please confirm your understanding in your response letter.
Response: This confirms our understanding that it is the staff’s position that the Revised Separateness Test (as defined in our prior response letter) is not the appropriate analytical framework for determining whether PWAI and our Asset Management Subsidiaries are integrated under general Advisers Act principles.
If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.
Very truly yours,
/s/ Hongtao Shi
Show Raw Text
CORRESP
1
filename1.htm
Prestige Wealth Inc.
June 8, 2023
Via EDGAR
Ms. Madeleine Mateo
Ms. Susan Block
Division of Corporation Finance
Office of Financial Services
U.S. Securities and Exchange Commission
Re:
Prestige Wealth Inc.
Amendment No. 4 to Registration Statement on Form F-1
Filed May 12, 2023
File No. 333-267999
Dear Ms. Mateo and Ms. Block:
This letter is in response to the letter dated
May 30, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Prestige Wealth Inc. (the “Company”, “we”, or “our”). For ease of
reference, we have recited the Commission’s comment in this response.
Amendment No. 4 to Registration Statement on
Form F-1 filed May 12, 2023
General
1. We note your response to our prior comment
1 and reissue the comment in part. As such, the staff reiterates that the Revised Separateness Test (as defined in your response letter)
is not the appropriate analytical framework in this scenario where the staff’s question, in the first instance, is whether PWAI,
on the one hand, and the Asset Management Subsidiaries, on the other, are integrated under general Advisers Act principles. Please confirm
your understanding in your response letter.
Response: This confirms our understanding
that it is the staff’s position that the Revised Separateness Test (as defined in our prior response letter) is not the appropriate
analytical framework for determining whether PWAI and our Asset Management Subsidiaries are integrated under general Advisers Act principles.
If you have any questions, please do not hesitate
to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.
Very truly yours,
/s/ Hongtao Shi
Name:
Hongtao Shi
Title:
Chief Executive Officer