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United States securities and exchange commission logo
January 26, 2023
Jing Tang
Chief Financial Officer
Able View Global Inc.
Room 1803, Shanghai International Building
511 Weihai Road, Jing’an District
Shanghai
China
Re:Able View Global Inc.
Draft Registration Statement on Form F-4
Submitted December 27, 2022
CIK No. 0001957489
Dear Jing Tang:
            We have reviewed your 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.
Draft Registration Statement on Form F-4 Submitted December 27, 2022
Cover Page
1.Where you disclose that you are not a Chinese based operating company and your
operations are conducted by your subsidiaries in China, clarify that this structure involves
unique risks to investors. Your disclosure should acknowledge that Chinese regulatory
authorities could disallow this structure, which would likely result in a material change in
your operations and/or a material change in the value of the securities you are registering
for sale, including that it could cause the value of such securities to significantly decline

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 January 26, 2023 Page 2
 FirstName LastName
Jing Tang
Able View Global Inc.
January 26, 2023
Page 2
or become worthless. Provide a cross-reference to your detailed discussion of risks facing
the company and the offering as a result of this structure.
2.Please disclose whether and how the Holding Foreign Companies Accountable Act and
related regulations will affect your company.
3.Given your operations located in Hong Kong, please discuss the laws and regulations in
Hong Kong, as applicable, as well as the related risks and consequences. An example of
such location-specific regulations that should be discussed includes:
•Enforceability of civil liabilities in Hong Kong;
•China's Enterprise Tax Law;
•Regulatory actions related to data security or anti-monopoly concerns in Hong Kong
and its potential impact on your ability to conduct business, accept foreign investment
or list on a U.S./foreign exchange; and
•Risk factor disclosure explaining whether there are laws/regulations in Hong Kong
that result in oversight over data security, how this oversight impacts the company’s
business and the offering, and to what extent the company believes that it is
compliant with the regulations or policies that have been issued.
4.Provide a description of how cash is transferred through your organization and disclose
your intentions to distribute earnings or transfer cash between entities in the future. State
whether any transfers, dividends, or distributions have been made to date between the
holding company, any of its subsidiaries or to investors, and quantify the amounts where
applicable. To the extent you have cash management policies that dictate how funds are
transferred between you, your subsidiaries or investors, summarize the policies on your
cover page and in the prospectus summary, and disclose the source of such policies (e.g.,
whether they are contractual in nature, pursuant to regulations, etc.); alternatively, state on
the cover page and in the prospectus summary that you have no such cash management
policies that dictate how funds are transferred.
5.Please amend your disclosure here and in the summary risk factors and risk factors
sections to state that, to the extent cash in the business is in the PRC/Hong Kong or a
PRC/Hong Kong entity, the funds may not be available to fund operations or for other use
outside of the PRC/Hong Kong due to interventions in or the imposition of restrictions
and limitations on the ability of you or your subsidiaries by the PRC government to
transfer cash. On the cover page, provide cross-references to these other discussions.
6.Discuss whether there are limitations on your ability to transfer cash between you, your
subsidiaries or investors. Provide a cross-reference to your discussion of this issue in your
summary, summary risk factors, and risk factors sections, as well.
Defined Terms, page 2
7.Please ensure that defined terms are consistently defined. As one example only, please
provide a definition of "Merger" in this section consistent with the definition provided on
page 5. Please also revise to include the definition of "Initial Shareholder."

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Able View Global Inc.
January 26, 2023
Page 3
Summary of the Material Terms of the Business Combination
General Description of the Business Combination Agreement, page 4
8.For purposes of determining the amount of shares to be issued to the Sellers, include
illustrative examples of how the Exchange Consideration could be determined assuming a
certain number of shares outstanding and certain redemption prices, and disclose how the
total amount of consideration could fluctuate depending upon how the inputs change over
time.
Questions and Answers About the Proposals, page 17
9.We note your redemption scenarios on page 22. Please add a question and answer to
disclose the equity stakes of each group of shareholders in a chart or another easily
understandable presentation in this section to show the potential impact of redemptions on
the per share value of the shares owned by non-redeeming shareholders by including a
sensitivity analysis showing a range of redemption scenarios, including minimum,
maximum and interim redemption levels.
10.We note references to certain parties agreeing to waive certain business combination or
Trust Account rights, such as on page 22. If any of those waivers included waiving
shareholder redemption rights, then please state as much and describe any consideration
provided in exchange for this agreement.
Did the HMAC's board of directors obtain a fairness opinion in determining whether to proceed
with the Business Combination?, page 21
11.We note that the HMAC Board received a valuation opinion from CHFT. Please revise to
discuss what consideration was given to this opinion by the Board in recommending the
transaction to shareholders.
What happens to the funds deposited in the Trust Account after the consummation of the
Business Combination?, page 27
12.Elaborate upon this response to provide the information you present here in tabular and
quantified format, and utilize various redemption scenarios to depict the possible
outcomes.  Include the minimum PIPE financing commitment of $60 million.
Summary of the Proxy Statement/Prospectus, page 30
13.Revise to move this section up so that it appears at the forepart of the prospectus and
before the Q&A section, consistent with Item 3 of Form F-4. Also, consider revising your
"Summary of the Material Term of the Business Combination" so that it presents a more
condensed version of the terms, as it appears to repeat verbatim much of the disclosure
that appears later in the prospectus under "The Business Combination Proposal."

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Able View Global Inc.
January 26, 2023
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14.Disclose each permission or approval that you, HMAC, or your subsidiaries are required
to obtain from Chinese authorities to operate your business and to offer the securities
being registered to foreign investors. State whether you, your subsidiaries are covered by
permissions requirements from the China Securities Regulatory Commission (CSRC),
Cyberspace Administration of China (CAC) or any other governmental agency that is
required to approve your operations, and state affirmatively whether you have received all
requisite permissions or approvals and whether any permissions or approvals have been
denied. Please also describe the consequences to you and your investors if you, HMAC, or
your subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii)
inadvertently conclude that such permissions or approvals are not required, or (iii)
applicable laws, regulations, or interpretations change and you are required to obtain such
permissions or approvals in the future.
15.Provide a clear description of how cash and other assets are transferred through your
organization. Quantify any cash flows and transfers of other assets by type that have
occurred between the holding company, its subsidiaries, and direction of transfer.
Quantify any dividends or distributions that a subsidiary has made to the holding company
and which entity made such transfer, and their tax consequences. Similarly quantify
dividends or distributions made to U.S. investors, the source, and their tax consequences.
Your disclosure should make clear if no transfers, dividends, or distributions have been
made to date. Describe any restrictions on foreign exchange and your ability to transfer
cash between entities, across borders, and to U.S. investors. Describe any restrictions and
limitations on your ability to distribute earnings from the company, including your
subsidiaries, to the parent company and U.S. investors as well as the ability to settle
amounts owed.
Quorum and Vote of HMAC's Shareholders, page 34
16.Ensure that your disclosure is consistent about the level of shareholder approval required
to take action.  For example, you state here that the Organizational Documents Advisory
Proposals will require the affirmative vote of the holders of a majority of the then-
outstanding ordinary shares of HMAC that are present and voted at the meeting, however,
elsewhere your disclosure brackets this proposal alongside the Charter Proposal, which
requires a special resolution.
Interests of HMAC's Sponsor, Directors and Officers in the Business Combination, page 35
17.Please ensure that for each category described here you quantify the aggregate dollar
amount and describe the nature of what the sponsor and its affiliates have at risk that
depends on completion of a business combination. For example, disclose the amount of
consideration paid for the 341,500 Private Placement Units, the amount of expenses borne
by your officers, directors or Founder to date and the outstanding amounts due under any
Working Capital Loans.

 FirstName LastNameJing Tang
 Comapany NameAble View Global Inc.
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 FirstName LastName
Jing Tang
Able View Global Inc.
January 26, 2023
Page 5
18.We note your disclosure on pages 27 and 37 discussing Working Capital Loans that may
be convertible into Working Capital Units upon consummation of the business
combination. Please provide your analysis demonstrating how this agreement complies
with Rule 14e-5 and Tender Offer Compliance and Disclosure Interpretation 166.01.
19.We understand from exhibit 4.6 that the sponsor will receive additional securities pursuant
to an anti-dilution adjustment for the company’s additional financing activities. Please
quantify the number and value of securities the sponsor will receive. In addition, disclose
the ownership percentages in the company before and after the additional financing to
highlight dilution to public stockholders.
Summary of Risk Factors
Risks Related to Doing Business in the People's Republic of China, page 39
20.We note your disclosure summarizing the risks on being based in or having the majority
of the company's operations in China poses to investors. In addition, please also include a
discussion of risks arising from the legal system in China, including risks and
uncertainties regarding the enforcement of laws and that rules and regulations in China
can change quickly with little advance notice; and the risk that the Chinese government
may intervene or influence your operations at any time, or may exert more control over
offerings conducted overseas and/or foreign investment in China-based issuers, which
could result in a material change in your operations and/or the value of the securities you
are registering for sale. Acknowledge any risks that any actions by the Chinese
government to exert more oversight and control over offerings that are conducted overseas
and/or foreign investment in China-based issuers could significantly limit or completely
hinder your ability to offer or continue to offer securities to investors and cause the value
of such securities to significantly decline or be worthless. In addition, please include
cross-references to each individual risk factor included in this sub-section.
Selected Unaudited Pro Forma Condensed Financial Statements, page 43
21.The numbers of pro forma weighted average shares outstanding – basic and diluted and
the amounts of pro forma net income per share – basic and diluted under both scenarios
for the 6 months ended June 30, 2022 appear to be inconsistent with those stated in your
unaudited pro forma combined statement of operations for the 6 months ended June 30,
2022 on page 152.  The selected unaudited pro forma condensed combined statement of
income – year ended December 31, 2021 presented in this section is inconsistent with
your unaudited pro forma combined statement of operations for the year ended December
31, 2021 on page 153.  Please reconcile and revise these disclosures.
Risk Factors, page 45
22.Please highlight the material risks to public warrant holders, including those arising from
differences between the private placement and public warrants. Clarify whether recent
common stock trading prices exceed the threshold that would allow the company to

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redeem public warrants. Clearly explain the steps, if any, the company will take to notify
all shareholders, including beneficial owners, regarding when the warrants become
eligible for redemption.
Risks Related to Able View's Business and Industry
If we are unable to retain our existing brand partners, our results of operations could be
materially and adversely affected, page 46
23.We note your indication here that net revenues related to your top three brand partners as
ranked by net revenues comprised approximately 57%, 10% and 8% of your total net
revenues, respectively, in 2021.  However, we are unable to reconcile these amounts with
the disclosure that appears in footnote 10 to your financial statements, where you discuss
Customer and Vendor concentration.  Please revise or advise. Also, please update this risk
factor to reflect the status of the contract renewal process with your brand partners.
Substantial uncertainties exist with respect to the Cybersecurity Law and the impact it may have
on our business operations, page 60
24.We note your disclosure that you might be deemed a “network platform operator” and
thus subject to the requirements of the Cybersecurity Law and the New Measures for
Cyber Security Review and that you have prepared requisite documents and are planning
to file these documents with the relevant government authority for cybersecurity review.
Revise to elaborate upon this disclosure to explain the status of your application and next
steps. Clarify whether you also have personal information data of more than one million
users, such that you are obligated to apply before listing on NASDAQ. Update your
disclosure that appears under "Regulations Applicable to Able View."
A severe or prolonged downturn in the glo