SEC Comment Letter 0000000000-22-012602 to FBS Global Ltd (FBGL) (CIK 0001938534) (FBGL)
FBS Global Ltd (FBGL) (CIK 0001938534)
Date: Nov. 21, 2022 · CIK: 0001938534 · Accession: 0000000000-22-012602
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United States securities and exchange commission logo
November 21, 2022
Kelvin Ang
Chief Executive Officer
FBS Global Limited
74 Tagore Lane, #02-00
Sindo Industrial Estate
Singapore 787498
Re:FBS Global Limited
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted November 4, 2022
CIK No. 0001938534
Dear Kelvin Ang:
We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. 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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form F-1 submitted November 4, 2022
The trading price of our Ordinary Shares may be volatile, page 23
1.Please revise this risk factor to address the potential for rapid and substantial price
volatility 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 condition or
prospects, making it difficult for prospective investors to assess the rapidly changing value
of your stock.
FirstName LastNameKelvin Ang
Comapany NameFBS Global Limited
November 21, 2022 Page 2
FirstName LastName
Kelvin Ang
FBS Global Limited
November 21, 2022
Page 2
Compensation of Directors and Executive Officers, page 93
2.We note your response to prior comment 14. Please expand the reference to "All of
[y]our executive officers, other than Kelvin Ang, have employment agreements setting
forth the terms and benefits, including that they are at-will employees" to discuss the
material terms of the employment agreements.
General
3.We note your response to prior comment 15. As previously requested, please update the
disclosure in the Related Party Transactions section.
4.Please reconcile your response to prior comment 16 with the information in the third
column of the table and related notes below the table.
5.We note your response to prior comment 20. Please reconcile your disclosure throughout
your document, such as pages 10, 26 and 27, regarding whether you will rely on the home
country and controlled company exemptions you mention.
You may contact Mindy Hooker, Staff Accountant, at 202-551-3732 or Kevin Woody,
Accounting Branch Chief, at 202-551-3629 if you have questions regarding comments on the
financial statements and related matters. Please contact Thomas Jones, Staff Attorney, at 202-
551-3602 or Geoff Kruczek, Senior Attorney, at 202-551-3641 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: David L. Ficksman, Esq.