SEC Comment Letter 0000000000-22-012316 to CBL International Ltd (BANL) (CIK 0001914805) (BANL)
CBL International Ltd (BANL) (CIK 0001914805)
Date: Nov. 14, 2022 · CIK: 0001914805 · Accession: 0000000000-22-012316
AI Filing Summary & Sentiment
File numbers found in text: 333-267077
Letter
United States securities and exchange commission logo November 14, 2022 Teck Chia Chief Executive Officer CBL International Ltd Suite 19-9-6, Level 9, UOA Centre No. 19 Jalan Pinang 50450 Kuala Lumpur, Malaysia Re:CBL International Ltd Amendment No. 5 to Registration Statement on Form F-1 Filed November 4, 2022 File No. 333-267077 Dear Teck Chia: We have reviewed your amended registration statement and have the following comment. In our comment, 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 comment applies 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 the comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our October 4, 2022 letter. Amendment No. 5 to Registration Statement on Form F-1 Risk Factors, page 17 1.We note recent instances of extreme stock price run-ups followed by rapid price declines and stock price volatility seemingly unrelated to company performance following a number of recent initial public offerings, particularly among companies with relatively smaller public floats. Revise to include a separate risk factor addressing the potential for rapid and substantial price volatility and any known factors particular to your offering that may add to this risk and discuss the risks to investors when investing in stock where the price is changing rapidly. Clearly state that such volatility, including any stock-run up, may be unrelated to your actual or expected operating performance and financial
FirstName LastNameTeck Chia Comapany NameCBL International Ltd November 14, 2022 Page 2 FirstName LastName Teck Chia CBL International Ltd November 14, 2022 Page 2 condition or prospects, making it difficult for prospective investors to assess the rapidly changing value of your stock. You may contact Patrick Kuhn at 202-551-3308 or Lyn Shenk at 202-551-3380 if you have questions regarding comments on the financial statements and related matters. Please contact Scott Anderegg at 202-551-3342 or Mara Ransom at 202-551-3264 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
November 14, 2022
Teck Chia
Chief Executive Officer
CBL International Ltd
Suite 19-9-6, Level 9, UOA Centre
No. 19 Jalan Pinang
50450 Kuala Lumpur, Malaysia
Re:CBL International Ltd
Amendment No. 5 to Registration Statement on Form F-1
Filed November 4, 2022
File No. 333-267077
Dear Teck Chia:
We have reviewed your amended registration statement and have the following
comment. In our comment, 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 comment applies 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 the comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our October 4, 2022 letter.
Amendment No. 5 to Registration Statement on Form F-1
Risk Factors, page 17
1.We note recent instances of extreme stock price run-ups followed by rapid price declines
and stock price volatility seemingly unrelated to company performance following a
number of recent initial public offerings, particularly among companies with relatively
smaller public floats. Revise to include a separate risk factor addressing the potential for
rapid and substantial price volatility and any known factors particular to your offering that
may add to this risk and discuss the risks to investors when investing in stock where the
price is changing rapidly. Clearly state that such volatility, including any stock-run up,
may be unrelated to your actual or expected operating performance and financial
FirstName LastNameTeck Chia
Comapany NameCBL International Ltd
November 14, 2022 Page 2
FirstName LastName
Teck Chia
CBL International Ltd
November 14, 2022
Page 2
condition or prospects, making it difficult for prospective investors to assess the rapidly
changing value of your stock.
You may contact Patrick Kuhn at 202-551-3308 or Lyn Shenk at 202-551-3380 if you
have questions regarding comments on the financial statements and related matters. Please
contact Scott Anderegg at 202-551-3342 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services