SEC Comment Letter 0000000000-22-013272 to Multi Ways Holdings Ltd (MWG) (CIK 0001941500) (MWG)
Multi Ways Holdings Ltd (MWG) (CIK 0001941500)
Date: Dec. 9, 2022 · CIK: 0001941500 · Accession: 0000000000-22-013272
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United States securities and exchange commission logo December 9, 2022 James Lim Eng Hock Chief Executive Officer Multi Ways Holdings Limited 3E Gul Circle Singapore 629633 Re:Multi Ways Holdings Limited Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted November 23, 2022 CIK No. 0001941500 Dear James Lim Eng Hock: 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 23, 2022 Report of Independent Registered Public Accounting Firm, page F-25 1.We note your response to comment 2 and your statement that the audit report date in the initial filing "was incorrect due to clerical error." Considering the initial filing was submitted on August 26, 2022, an audit report dated October 21, 2022 would not have been possible. Accordingly, please clarify why the audit report date changed between filings and tell us how your audit report date complies with PCAOB Auditing Standard 3110. In doing so, tell us if the financial statements included in any prior filings were submitted prior to audit completion.
FirstName LastNameJames Lim Eng Hock Comapany NameMulti Ways Holdings Limited December 9, 2022 Page 2 FirstName LastName James Lim Eng Hock Multi Ways Holdings Limited December 9, 2022 Page 2 You may contact Andi Carpenter at 202-551-3645 or Andrew Blume at 202-551-3254 if you have questions regarding comments on the financial statements and related matters. Please contact Patrick Fullem at 202-551-8337 or Jay Ingram at 202-551-3397 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Jason Ye
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United States securities and exchange commission logo
December 9, 2022
James Lim Eng Hock
Chief Executive Officer
Multi Ways Holdings Limited
3E Gul Circle
Singapore 629633
Re:Multi Ways Holdings Limited
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted November 23, 2022
CIK No. 0001941500
Dear James Lim Eng Hock:
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 23, 2022
Report of Independent Registered Public Accounting Firm, page F-25
1.We note your response to comment 2 and your statement that the audit report date in the
initial filing "was incorrect due to clerical error." Considering the initial filing was
submitted on August 26, 2022, an audit report dated October 21, 2022 would not have
been possible. Accordingly, please clarify why the audit report date changed between
filings and tell us how your audit report date complies with PCAOB Auditing Standard
3110. In doing so, tell us if the financial statements included in any prior filings were
submitted prior to audit completion.
FirstName LastNameJames Lim Eng Hock
Comapany NameMulti Ways Holdings Limited
December 9, 2022 Page 2
FirstName LastName
James Lim Eng Hock
Multi Ways Holdings Limited
December 9, 2022
Page 2
You may contact Andi Carpenter at 202-551-3645 or Andrew Blume at 202-551-3254 if
you have questions regarding comments on the financial statements and related matters. Please
contact Patrick Fullem at 202-551-8337 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Jason Ye