SEC Comment Letter 0000000000-23-008817 to AMTD IDEA GROUP (AMTD) (CIK 0001769731) (AMTD)
AMTD IDEA GROUP (AMTD) (CIK 0001769731)
Date: Aug. 14, 2023 · CIK: 0001769731 · Accession: 0000000000-23-008817
AI Filing Summary & Sentiment
File numbers found in text: 001-39006
Letter
United States securities and exchange commission logo August 14, 2023 Xavier Zee Chief Financial Officer AMTD IDEA Group 23/F Nexxus Building 41 Connaught Road Central Hong Kong Re:AMTD IDEA Group Form 20-F for the Fiscal Year Ended December 31, 2022 Filed April 28, 2023 File No. 001-39006 Dear Xavier Zee: 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 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 these comments 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 these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 21, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 120 1.We note your response to comment 3. Item 16I(b) of Form 20-F states: “Also, any such identified foreign issuer that uses a variable-interest entity or any similar structure [emphasis added] that results in additional foreign entities being consolidated in the financial statements of the registrant is required to provide the below disclosures for itself and its consolidated foreign operating entity or entities.” Additionally, page 15 of our Release No. 34-93701, “Holding Foreign Companies Accountable Act Disclosure,” clarifies that a registrant should “look through a VIE or any structure [emphasis added] that results in additional foreign entities being consolidated in the financial statements of the registrant and provide the required disclosures about any consolidated operating company or companies in the relevant jurisdiction.” As previously requested, please
FirstName LastNameXavier Zee Comapany NameAMTD IDEA Group August 14, 2023 Page 2 FirstName LastName Xavier Zee AMTD IDEA Group August 14, 2023 Page 2 provide us with the information required by Items 16I(b)(2), (b)(3) and (b)(5) for all of your consolidated foreign operating entities in your supplemental response. 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 Austin Pattan, Staff Attorney, at (202) 551-6756 or Jennifer Gowetski, Staff Attorney, at (202) 551-3401 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Shu Du
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United States securities and exchange commission logo
August 14, 2023
Xavier Zee
Chief Financial Officer
AMTD IDEA Group
23/F Nexxus Building
41 Connaught Road Central
Hong Kong
Re:AMTD IDEA Group
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 28, 2023
File No. 001-39006
Dear Xavier Zee:
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 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 these comments 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 these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
July 21, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 120
1.We note your response to comment 3. Item 16I(b) of Form 20-F states: “Also, any such
identified foreign issuer that uses a variable-interest entity or any similar structure
[emphasis added] that results in additional foreign entities being consolidated in the
financial statements of the registrant is required to provide the below disclosures for itself
and its consolidated foreign operating entity or entities.” Additionally, page 15 of our
Release No. 34-93701, “Holding Foreign Companies Accountable Act Disclosure,”
clarifies that a registrant should “look through a VIE or any structure [emphasis added]
that results in additional foreign entities being consolidated in the financial statements of
the registrant and provide the required disclosures about any consolidated operating
company or companies in the relevant jurisdiction.” As previously requested, please
FirstName LastNameXavier Zee
Comapany NameAMTD IDEA Group
August 14, 2023 Page 2
FirstName LastName
Xavier Zee
AMTD IDEA Group
August 14, 2023
Page 2
provide us with the information required by Items 16I(b)(2), (b)(3) and (b)(5) for all of
your consolidated foreign operating entities in your supplemental response.
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 Austin Pattan, Staff Attorney, at (202) 551-6756 or Jennifer Gowetski,
Staff Attorney, at (202) 551-3401 with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Shu Du