SEC Comment Letter for HAIBO SYM, INC. (CIK 0001809964) — Jun 18, 2020
HAIBO SYM, INC. (CIK 0001809964)
Date: June 18, 2020 · CIK: 0001809964 · Accession: 0000000000-20-005462
AI Filing Summary & Sentiment
File numbers found in text: 024-11203
Letter
United States securities and exchange commission logo June 18, 2020 Benny Zhu Chief Executive Officer Haibo SYM, Inc. 41 Meadowview Lane Berkeley Heights, New Jersey 07922-1327 Re:Haibo SYM, Inc. Amendment No. 1 to Offering Statement on Form 1-A Filed June 4, 2020 File No. 024-11203 Dear Mr. Zhu: We have reviewed your amended offering 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 offering 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 offering statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our May 22, 2020 letter. Amendment No. 1 to Offering Statement on Form 1-A Exhibit 11 1.Please revise the consent of your independent auditor to refer to the correct audit report date of April 27, 2020. General 2.We note your response to prior comment 8 and that the company does not intend to become an Exchange Act reporting company until the offering is completed. Please revise to provide additional disclosure regarding the consequences of not becoming a Exchange Act reporting company, including the applicability of Emerging Growth Company status and what reporting requirements the company will be subject to prior to
FirstName LastNameBenny Zhu Comapany NameHaibo SYM, Inc. June 18, 2020 Page 2 FirstName LastName Benny Zhu Haibo SYM, Inc. June 18, 2020 Page 2 becoming an Exchange Act reporting company. You may contact Frank Knapp, Staff Accountant, at (202) 551-3805 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments on the financial statements and related matters. Please contact Matthew Derby, Staff Attorney, at (202) 551-3334 or Matthew Crispino, Staff Attorney, at (202) 551-3456 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Frank J. Hariton
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United States securities and exchange commission logo
June 18, 2020
Benny Zhu
Chief Executive Officer
Haibo SYM, Inc.
41 Meadowview Lane
Berkeley Heights, New Jersey 07922-1327
Re:Haibo SYM, Inc.
Amendment No. 1 to Offering Statement on Form 1-A
Filed June 4, 2020
File No. 024-11203
Dear Mr. Zhu:
We have reviewed your amended offering 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 offering 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 offering statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our May 22, 2020 letter.
Amendment No. 1 to Offering Statement on Form 1-A
Exhibit 11
1.Please revise the consent of your independent auditor to refer to the correct audit report
date of April 27, 2020.
General
2.We note your response to prior comment 8 and that the company does not intend to
become an Exchange Act reporting company until the offering is completed. Please
revise to provide additional disclosure regarding the consequences of not becoming
a Exchange Act reporting company, including the applicability of Emerging Growth
Company status and what reporting requirements the company will be subject to prior to
FirstName LastNameBenny Zhu
Comapany NameHaibo SYM, Inc.
June 18, 2020 Page 2
FirstName LastName
Benny Zhu
Haibo SYM, Inc.
June 18, 2020
Page 2
becoming an Exchange Act reporting company.
You may contact Frank Knapp, Staff Accountant, at (202) 551-3805 or Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments on the
financial statements and related matters. Please contact Matthew Derby, Staff Attorney, at (202)
551-3334 or Matthew Crispino, Staff Attorney, at (202) 551-3456 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Frank J. Hariton