SEC Comment Letter for BGM Group Ltd. (BGM) (CIK 0001779578) (BGM) — Apr 22, 2020
BGM Group Ltd. (BGM) (CIK 0001779578)
Date: April 22, 2020 · CIK: 0001779578 · Accession: 0000000000-20-003426
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File numbers found in text: 333-234460
Letter
April 21, 2020 Zhanchang Xin Chief Executive Officer Qilian International Holding Group Ltd Jiuquan Economic and Technological Development Zone Jiuquan City, Gansu Province People’s Republic of China Re:Qilian International Holding Group Ltd Amendment No. 3 to Registration Statement on Form F-1 Filed April 8, 2020 File No. 333-234460 Dear Mr. Xin: We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Amendment No. 3 to Registration Statement on Form F-1 Note 1 - Organization and Description of Business, page F-6 1.We note that you have revised your Gansu QLS ownership disclosure through March 31, 2020. Please have your auditors include this note in their dual dated note of their audit opinion, or revise such disclosure to match the existing dates of your audited financial statements. General 2.Please revise to provide a properly dated consent from the independent registered public accountant in this filing, and any future amendments.
FirstName LastNameZhanchang Xin Comapany NameQilian International Holding Group Ltd April 21, 2020 Page 2 FirstName LastName Zhanchang Xin Qilian International Holding Group Ltd April 21, 2020 Page 2 You may contact Bonnie Baynes at 202-551-4924 or Sharon Blume at 202-551-3474 if you have questions regarding comments on the financial statements and related matters. Please contact Sonia Bednarowski at 202-551-3666 or Dietrich King at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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April 21, 2020
Zhanchang Xin
Chief Executive Officer
Qilian International Holding Group Ltd
Jiuquan Economic and Technological Development Zone
Jiuquan City, Gansu Province
People’s Republic of China
Re:Qilian International Holding Group Ltd
Amendment No. 3 to Registration Statement on Form F-1
Filed April 8, 2020
File No. 333-234460
Dear Mr. Xin:
We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 3 to Registration Statement on Form F-1
Note 1 - Organization and Description of Business, page F-6
1.We note that you have revised your Gansu QLS ownership disclosure through March 31,
2020. Please have your auditors include this note in their dual dated note of their audit
opinion, or revise such disclosure to match the existing dates of your audited financial
statements.
General
2.Please revise to provide a properly dated consent from the independent registered public
accountant in this filing, and any future amendments.
FirstName LastNameZhanchang Xin
Comapany NameQilian International Holding Group Ltd
April 21, 2020 Page 2
FirstName LastName
Zhanchang Xin
Qilian International Holding Group Ltd
April 21, 2020
Page 2
You may contact Bonnie Baynes at 202-551-4924 or Sharon Blume at 202-551-3474 if
you have questions regarding comments on the financial statements and related matters. Please
contact Sonia Bednarowski at 202-551-3666 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences