UPLOAD Filing
LOBO TECHNOLOGIES LTD.
Date: June 27, 2025 · CIK: 0001932072 · Accession: 0000000000-25-006763
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-41981
Letter
Re: LOBO EV Technologies Ltd. Annual Report on Form 20-F for the Fiscal Year Ended December 31, Filed April 28, 2025 File No. 001-41981 Dear Huajian Xu:
June 27, 2025
Huajian Xu Chief Executive Officer LOBO EV Technologies Ltd. Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd Xinwu District, Wuxi, Jiangsu People s Republic of China, 214111
We have limited our review of your filing to the financial statements and related disclosures and have the following comments.
Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Annual Report on Form 20-F for the Fiscal Year Ended December 31, 2024 Item 15. Controls and Procedures, page 80
1. We note you have disclosed under this heading that controls and procedures are not required. Please revise to include the disclosures required by Item 15(a), Disclosure Controls and Procedures, and Item 15(b)(1) through (b)(3), Management's Annual Report on Internal Control over Financial Reporting, pursuant to the Form 20-F. As an emerging growth company, you are not required to comply with Item 15(b)(4) and Item 15(c) of the Form 20-F with respect to an attestation report on internal control over financial reporting by your registered public accounting firm. Please also provide the disclosures required by Item 15(d) of the Form 20-F. Refer to Instruction 1 to Item 15 of the Form 20-F, where compliance with paragraphs (b) and (c) were not required in the first fiscal year you were required to file an annual report, or the transition period, but are are required to comply in the second annual reporting year (i.e., your fiscal year ended December 31, 2024). Please amend your December 31, 2024 Form June 27, 2025 Page 2
20-F in its entirety to comply, including providing updated Exhibit 12 & Certifications from the CEO and CFO. In addition, the Exhibit 12 Certifications should include all disclosures for paragraph 4, as we note you currently have omitted the paragraph 4(b) required language. We refer you to the Staff's Compliance & Disclosure Interpretations ("C&DIs") of Regulation S-K, section 246.13.
2. We further note from Risk Factors, page 2, that you identified two material weaknesses in internal control over financial reporting. Your revised disclosures under Item 15 should also discuss these material weaknesses and any remediation actions or plans you have implemented to address the material weaknesses. Please be advised we would anticipate both your conclusions, under Item 15 of the Form 20-F, of disclosure controls and procedures and internal control over financial reporting as of December 31, 2024 to be concluded as not effective due to the material weaknesses. Refer to Section II.B.3(c) of SEC Release No. 33-8238.
In closing, 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 Beverly Singleton at 202-551-3328 or Melissa Gilmore at 202-551- 3777 with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing
Show Raw Text
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<TEXT>
June 27, 2025
Huajian Xu
Chief Executive Officer
LOBO EV Technologies Ltd.
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People s Republic of China, 214111
Re: LOBO EV Technologies Ltd.
Annual Report on Form 20-F for the Fiscal Year Ended December 31,
2024
Filed April 28, 2025
File No. 001-41981
Dear Huajian Xu:
We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.
Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this letter, we may have additional
comments.
Annual Report on Form 20-F for the Fiscal Year Ended December 31, 2024
Item 15. Controls and Procedures, page 80
1. We note you have disclosed under this heading that controls and
procedures are not
required. Please revise to include the disclosures required by Item
15(a), Disclosure
Controls and Procedures, and Item 15(b)(1) through (b)(3), Management's
Annual
Report on Internal Control over Financial Reporting, pursuant to the
Form 20-F. As
an emerging growth company, you are not required to comply with Item
15(b)(4) and
Item 15(c) of the Form 20-F with respect to an attestation report on
internal control
over financial reporting by your registered public accounting firm.
Please also provide
the disclosures required by Item 15(d) of the Form 20-F. Refer to
Instruction 1 to Item
15 of the Form 20-F, where compliance with paragraphs (b) and (c) were
not required
in the first fiscal year you were required to file an annual report, or
the transition
period, but are are required to comply in the second annual reporting
year (i.e., your
fiscal year ended December 31, 2024). Please amend your December 31,
2024 Form
June 27, 2025
Page 2
20-F in its entirety to comply, including providing updated Exhibit 12 &
13
Certifications from the CEO and CFO. In addition, the Exhibit 12
Certifications
should include all disclosures for paragraph 4, as we note you currently
have omitted
the paragraph 4(b) required language. We refer you to the Staff's
Compliance
& Disclosure Interpretations ("C&DIs") of Regulation S-K, section
246.13.
2. We further note from Risk Factors, page 2, that you identified two
material
weaknesses in internal control over financial reporting. Your revised
disclosures
under Item 15 should also discuss these material weaknesses and any
remediation
actions or plans you have implemented to address the material
weaknesses. Please be
advised we would anticipate both your conclusions, under Item 15 of the
Form 20-F,
of disclosure controls and procedures and internal control over
financial reporting as
of December 31, 2024 to be concluded as not effective due to the
material
weaknesses. Refer to Section II.B.3(c) of SEC Release No. 33-8238.
In closing, 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 Beverly Singleton at 202-551-3328 or Melissa Gilmore at
202-551-
3777 with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing
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