SEC Comment Letter 0000000000-23-005785 to Roma Green Finance Ltd (ROMA)
Roma Green Finance Ltd
Date: June 1, 2023 · CIK: 0001945240 · Accession: 0000000000-23-005785
AI Filing Summary & Sentiment
Reasoning
Letter
United States securities and exchange commission logo June 1, 2023 Luk Huen Ling Claire Chairlady, Executive Director and Chief Executive Officer Roma Green Finance Limited Flat 605, 6/F., Tai Tung Building 8 Fleming Road Wanchai, Hong Kong Re:Roma Green Finance Ltd Amendment No. 6 to Draft Registration Statement on Form F-1 Submitted May 10, 2023 CIK No. 0001945240 Dear Luk Huen Ling Claire: 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. 6 to Draft Registration Statement on Form F-1 submitted May 10, 2023 Recent Regulatory Development in the PRC, page 14 1.We note your response to comment 1 and reissue in part. Please clarify if your senior managers in charge of your business operations and management are mostly citizens of the PRC or domiciled in mainland China. We note that your disclosure continues to refer to "PRC natural person" rather than clarifying citizenship or domicile.
FirstName LastNameLuk Huen Ling Claire Comapany NameRoma Green Finance Limited June 1, 2023 Page 2 FirstName LastName Luk Huen Ling Claire Roma Green Finance Limited June 1, 2023 Page 2 Financial Statements, page 115 2.Please update your financial statements in accordance with Item 8.A.4 of Form 20-F or include the representation noted in the Instruction 2 to Item 8.A.4 as an exhibit to your registration statement. You may contact Suying Li at 202-551-3335 or Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters. Please contact Kate Beukenkamp at 202-551-3861 or Erin Jaskot at 202-551-3442 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Celia Velletri
Show Raw Text
United States securities and exchange commission logo
June 1, 2023
Luk Huen Ling Claire
Chairlady, Executive Director and Chief Executive Officer
Roma Green Finance Limited
Flat 605, 6/F., Tai Tung Building
8 Fleming Road
Wanchai, Hong Kong
Re:Roma Green Finance Ltd
Amendment No. 6 to Draft Registration Statement on Form F-1
Submitted May 10, 2023
CIK No. 0001945240
Dear Luk Huen Ling Claire:
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. 6 to Draft Registration Statement on Form F-1 submitted May 10, 2023
Recent Regulatory Development in the PRC, page 14
1.We note your response to comment 1 and reissue in part. Please clarify if your senior
managers in charge of your business operations and management are mostly citizens of
the PRC or domiciled in mainland China. We note that your disclosure continues to refer
to "PRC natural person" rather than clarifying citizenship or domicile.
FirstName LastNameLuk Huen Ling Claire
Comapany NameRoma Green Finance Limited
June 1, 2023 Page 2
FirstName LastName
Luk Huen Ling Claire
Roma Green Finance Limited
June 1, 2023
Page 2
Financial Statements, page 115
2.Please update your financial statements in accordance with Item 8.A.4 of Form 20-F or
include the representation noted in the Instruction 2 to Item 8.A.4 as an exhibit to your
registration statement.
You may contact Suying Li at 202-551-3335 or Joel Parker at 202-551-3651 if you have
questions regarding comments on the financial statements and related matters. Please contact
Kate Beukenkamp at 202-551-3861 or Erin Jaskot at 202-551-3442 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Celia Velletri