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SEC Comment Letter 0000000000-23-009681 to Huize Holding Ltd (HUIZ)

Huize Holding Ltd
Date: Aug. 31, 2023 · CIK: 0001778982 · Accession: 0000000000-23-009681

AI Filing Summary & Sentiment

File numbers found in text: 001-39216

Date
August 31, 2023
Author
Not clearly detected
Form
UPLOAD
Company
Huize Holding Ltd

Letter

United States securities and exchange commission logo August 31, 2023 Ronald Tam Co-Chief Financial Officer Huize Holding Limited 49/F, Building T1, Qianhai Financial Centre, Linhai Avenue Qianhai Shenzhen-Hong Kong Cooperation Zone, Shenzhen 518000 People’s Republic of China Re:Huize Holding Limited Form 20-F for the Fiscal Year Ended December 31, 2022 File No. 001-39216 Dear Ronald Tam: 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. Form 20-F for the Fiscal Year Ended December 31, 2022 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 162 1.We note your statement that you reviewed your register of members and public filings made by your shareholders in connection with your required submission under paragraph (a). Please supplementally describe any additional materials that were reviewed and tell us whether you relied upon any legal opinions or third party certifications such as affidavits as the basis for your submission. In your response, please provide a similarly detailed discussion of the materials reviewed and legal opinions or third party certifications relied upon in connection with the required disclosures under paragraphs (b)(2) and (3). 2.In order to clarify the scope of your review, please supplementally describe the steps you have taken to confirm that none of the members of your board or the boards of your consolidated foreign operating entities are officials of the Chinese Communist Party. For instance, please tell us how the board members’ current or prior memberships on, or affiliations with, committees of the Chinese Communist Party factored into your determination. In addition, please tell us whether you have relied upon third party

FirstName LastNameRonald Tam Comapany NameHuize Holding Limited August 31, 2023 Page 2 FirstName LastName Ronald Tam Huize Holding Limited August 31, 2023 Page 2 certifications such as affidavits as the basis for your disclosure. 3.We note that your disclosures pursuant to Items 16I(b)(2), (b)(3) and (b)(5) are provided for “our company or any of our subsidiaries or the VIE.” We also note that your definition of “VIE” on page 1 of your Form 20-F only refers to Shenzhen Huiye Tianze Investment Holding Co., Ltd. and does not include the VIE’s subsidiaries. Please note that Item 16I(b) requires that you provide disclosures for yourself and your consolidated foreign operating entities, including variable interest entities or similar structures. •With respect to (b)(2), please supplementally clarify the jurisdictions in which your consolidated foreign operating entities are organized or incorporated and provide the percentage of your shares or the shares of your consolidated operating entities owned by governmental entities in each foreign jurisdiction in which you have consolidated operating entities in your supplemental response. •With respect to (b)(3) and (b)(5), please provide the required information for you and 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 Tyler Howes at 202-551-3370 or Jennifer Gowetski at 202-551-3401 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Haiping Li, Esq.

Show Raw Text
United States securities and exchange commission logo
August 31, 2023
Ronald Tam
Co-Chief Financial Officer
Huize Holding Limited
49/F, Building T1, Qianhai Financial Centre, Linhai Avenue
Qianhai Shenzhen-Hong Kong Cooperation Zone, Shenzhen 518000
People’s Republic of China
Re:Huize Holding Limited
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 001-39216
Dear Ronald Tam:
            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.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 162
1.We note your statement that you reviewed your register of members and public filings
made by your shareholders in connection with your required submission under paragraph
(a). Please supplementally describe any additional materials that were reviewed and tell us
whether you relied upon any legal opinions or third party certifications such as affidavits
as the basis for your submission. In your response, please provide a similarly detailed
discussion of the materials reviewed and legal opinions or third party certifications relied
upon in connection with the required disclosures under paragraphs (b)(2) and (3).
2.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party. For
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination. In addition, please tell us whether you have relied upon third party

 FirstName LastNameRonald Tam
 Comapany NameHuize Holding Limited
 August 31, 2023 Page 2
 FirstName LastName
Ronald Tam
Huize Holding Limited
August 31, 2023
Page 2
certifications such as affidavits as the basis for your disclosure.
3.We note that your disclosures pursuant to Items 16I(b)(2), (b)(3) and (b)(5) are provided
for “our company or any of our subsidiaries or the VIE.” We also note that your definition
of “VIE” on page 1 of your Form 20-F only refers to Shenzhen Huiye Tianze Investment
Holding Co., Ltd. and does not include the VIE’s subsidiaries. Please note that Item 16I(b)
requires that you provide disclosures for yourself and your consolidated foreign operating
entities, including variable interest entities or similar structures.
•With respect to (b)(2), please supplementally clarify the jurisdictions in which your
consolidated foreign operating entities are organized or incorporated and provide the
percentage of your shares or the shares of your consolidated operating entities owned
by governmental entities in each foreign jurisdiction in which you have consolidated
operating entities in your supplemental response.
•With respect to (b)(3) and (b)(5), please provide the required information for you and
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 Tyler Howes at 202-551-3370 or Jennifer Gowetski at 202-551-3401 with
any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:       Haiping Li, Esq.