Correspondence 0001493152-24-037688 from Plutus Financial Group Ltd (PLUT) (CIK 0001933021) (PLUT)
Plutus Financial Group Ltd (PLUT) (CIK 0001933021)
Date: Sept. 20, 2024 · CIK: 0001933021 · Accession: 0001493152-24-037688
AI Filing Summary & Sentiment
File numbers found in text: 333-276791
Referenced dates: September 16, 2024
Letter
VIA EDGAR Office of Finance Division of Corporation Finance Re: Plutus Financial Group Limited Amendment No. 4 to Registration Statement on Form F-1 Filed August 28, 2024 File No. 333-276791
Dear Ms. Bednarowski and Ms. Livingston:
We write on behalf of Plutus Financial Group Limited (the “Company”) in response to comments by the United States Securities and Exchange Commission (the “Commission”) in its letter dated September 16, 2024, commenting on Amendment No. 4 to the Company’s Registration Statement on Form F-1 filed August 28, 2024 (the “Registration Statement”).
Titling and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment letter.
Amendment No. 4 to Registration Statement on Form F-1
Margin Financing, page 4
1. We note your disclosure that you assess collectability in part by ensuring the presence of an effective personal guarantee. Given that you do not appear to have received any collateral related funds from personal guarantees, please revise your disclosures to explain how you determine that a personal guarantee is effective or to clarify, if true, that you are just saying you ensure a personal guarantee is in place. In addition, disclose whether and how you assess changes in the financial capabilities of individuals providing a financial guarantee while a margin loan is outstanding.
Response: In response to this comment, the Company has amended the Registration Statement on page 4 and page 62 to clarify that its collectability assessments for margin loans are based on the market value of the pledged collateral and that, with regard to personal guarantees, the Company merely ensures that a legally effective and binding personal guarantee is in place. The financial capability of the individuals providing a personal guarantee is not subject to ongoing assessment.
United States Securities and Exchange Commission
Attn: Sonia Bednarowski and Jessica Livingston
September 20, 2024
Page 2 of 2
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Operating Expenses, page 63
2. Please revise your disclosures to quantify the amount of any principal and interest charged off in relation to the nine borrowers you discuss, and explain whether and where this is reflected in your roll forward.
Response: In response to this comment, the Company has amended the Registration Statement at pages 63 and 64 to provide a breakdown of the principal and interest charged off in relation to the nine borrowers (discussed in three categories) during 2023. In addition, a sentence was added above the table on page 64 to explain that the principal and interest charged off is shown on the line in the table titled “expected credit loss recognized.”
3. We note your revised disclosure on page 63 in response to comment 1. Please expand your disclosure to describe the material terms of the agreements with the account executives, including the termination provisions and any provisions related to the renegotiation of commission rates. In addition, please include these agreements as exhibits to your registration statement.
Response: In response to this comment, the Company has amended the Registration Statement at page 63 to explain that the contractual arrangements with account executives may be terminated by either party by giving one month notice and that the commission rates are revised at the discretion of the Company from time to time. For the year ended December 31, 2022 and 2023, there was no change to the formula for the commission rates. In addition, the Company’s current form of agreement for account executives has been filed with the Registration as new Exhibit 10.9.
Please feel free to contact me should you require additional information at (775) 234-5221 or jlaxague@cronelawgroup.com.
THE CRONE LAW GROUP, P.C.
By: /s/ Joe Laxague
Joe Laxague, Esq.
Show Raw Text
CORRESP
1
filename1.htm
Mark
E. Crone
Managing
Partner
mcrone@cronelawgroup.com
Joe
Laxague
Partner
jlaxague@cronelawgroup.com
VIA
EDGAR
September
20, 2024
THE
UNITED STATES SECURITIES
AND
EXCHANGE COMMISSION
Office
of Finance
Division
of Corporation Finance
Washington,
D.C. 20549
Attn:
Sonia Bednarowski and Jessica Livingston
Re:
Plutus
Financial Group Limited
Amendment
No. 4 to Registration Statement on Form F-1
Filed
August 28, 2024
File
No. 333-276791
Dear
Ms. Bednarowski and Ms. Livingston:
We
write on behalf of Plutus Financial Group Limited (the “Company”) in response to comments by the United States Securities
and Exchange Commission (the “Commission”) in its letter dated September 16, 2024, commenting on Amendment No. 4 to the Company’s
Registration Statement on Form F-1 filed August 28, 2024 (the “Registration Statement”).
Titling
and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment
letter.
Amendment
No. 4 to Registration Statement on Form F-1
Margin
Financing, page 4
1.
We note your disclosure that you assess collectability in part by ensuring the presence of an effective personal guarantee. Given that
you do not appear to have received any collateral related funds from personal guarantees, please revise your disclosures to explain how
you determine that a personal guarantee is effective or to clarify, if true, that you are just saying you ensure a personal guarantee
is in place. In addition, disclose whether and how you assess changes in the financial capabilities of individuals providing a financial
guarantee while a margin loan is outstanding.
Response:
In response to this comment, the Company has amended the Registration Statement on page 4 and page 62 to clarify that its collectability
assessments for margin loans are based on the market value of the pledged collateral and that, with regard to personal guarantees, the
Company merely ensures that a legally effective and binding personal guarantee is in place. The financial capability of the individuals
providing a personal guarantee is not subject to ongoing assessment.
United
States Securities and Exchange Commission
Attn:
Sonia Bednarowski and Jessica Livingston
September
20, 2024
Page
2 of 2
Management’s
Discussion and Analysis of Financial Condition and Results of Operations
Operating
Expenses, page 63
2.
Please revise your disclosures to quantify the amount of any principal and interest charged off in relation to the nine borrowers you
discuss, and explain whether and where this is reflected in your roll forward.
Response:
In response to this comment, the Company has amended the Registration Statement at pages 63 and 64 to provide a breakdown of the principal
and interest charged off in relation to the nine borrowers (discussed in three categories) during 2023. In addition, a sentence was added
above the table on page 64 to explain that the principal and interest charged off is shown on the line in the table titled “expected
credit loss recognized.”
3.
We note your revised disclosure on page 63 in response to comment 1. Please expand your disclosure to describe the material terms of
the agreements with the account executives, including the termination provisions and any provisions related to the renegotiation of commission
rates. In addition, please include these agreements as exhibits to your registration statement.
Response:
In response to this comment, the Company has amended the Registration Statement at page 63 to explain that the contractual arrangements
with account executives may be terminated by either party by giving one month notice and that the commission rates are revised at the
discretion of the Company from time to time. For the year ended December 31, 2022 and 2023, there was no change to the formula for the
commission rates. In addition, the Company’s current form of agreement for account executives has been filed with the Registration
as new Exhibit 10.9.
Please
feel free to contact me should you require additional information at (775) 234-5221 or jlaxague@cronelawgroup.com.
THE
CRONE LAW GROUP, P.C.
By:
/s/ Joe
Laxague
Joe Laxague, Esq.