Correspondence 0001213900-23-042021 from Solowin Holdings, Ltd. (SWIN) (CIK 0001959224) (AXG)
Solowin Holdings, Ltd. (SWIN) (CIK 0001959224)
Date: May 22, 2023 · CIK: 0001959224 · Accession: 0001213900-23-042021
AI Filing Summary & Sentiment
File numbers found in text: 333-271525
Referenced dates: May 15, 2023
Letter
SOLOWIN HOLDINGS
1910-1912A, Tower 3, China Hong Kong City
33 Canton Road, Tsim Sha Tsui, Kowloon
Hong Kong
May 22, 2023
Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Shannon Davis
John Spitz
Robert Arzonetti
Susan Block
Re: Solowin Holdings
Registration Statement on Form F-1
Filed April 28, 2023
File No. 333-271525
Ladies and Gentlemen:
We hereby submit the response of Solowin Holdings (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated May 15, 2023, providing the Staff’s comments with respect to the Company’s Registration Statement on Form F-1 filed on April 28, 2023. Concurrently with the submission of this letter, the Company is filing the Amendment No. 1 to the Registration Statement on Form F-1 (the “Amendment No. 1”) together with certain exhibits via EDGAR with the Commission.
Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.
Form F-1 filed April 28, 2023
General
1. Please revise your filing to include audited financial statements required by Item 8.A.4 of Form 20-F. Alternately, please file a representation as an exhibit to your filing that states that you are not required to comply with the 12-month requirement of audited financial statements in any other jurisdiction outside the United States and that complying with the 12-month requirement is impracticable or involves undue hardship. Refer to Instruction 2 of Item 8.A.4 of Form 20-F.
RESPONSE: In response to the Staff’s comment, we have filed a representation letter as Exhibit 99.7 to the Amendment No. 1 with the required statements pursuant to Instruction 2 of Item 8.A.4 of Form 20-F.
If you would like to discuss the response or if you would like to discuss any other matters, please contact the undersigned at (852)3428-3893 or Kevin Sun of Bevilacqua PLLC at (202) 869-0888 (ext. 101).
Sincerely,
SOLOWIN HOLDINGS
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SOLOWIN HOLDINGS
1910-1912A, Tower 3, China Hong Kong City
33 Canton Road, Tsim Sha Tsui, Kowloon
Hong Kong
May 22, 2023
Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Shannon Davis
John Spitz
Robert Arzonetti
Susan Block
Re: Solowin Holdings
Registration Statement on Form
F-1
Filed April 28, 2023
File No. 333-271525
Ladies and Gentlemen:
We hereby submit the response of Solowin
Holdings (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”) set forth in the Staff’s letter, dated May 15, 2023, providing the Staff’s
comments with respect to the Company’s Registration Statement on Form F-1 filed on April 28, 2023. Concurrently with the submission
of this letter, the Company is filing the Amendment No. 1 to the Registration Statement on Form F-1 (the “Amendment No. 1”)
together with certain exhibits via EDGAR with the Commission.
Unless the context indicates otherwise,
references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.
Form F-1 filed April 28, 2023
General
1. Please revise your filing to include audited financial statements required by
Item 8.A.4 of Form 20-F. Alternately, please file a representation as an exhibit to your filing that states that you are not required
to comply with the 12-month requirement of audited financial statements in any other jurisdiction outside the United States and that complying
with the 12-month requirement is impracticable or involves undue hardship. Refer to Instruction 2 of Item 8.A.4 of Form 20-F.
RESPONSE:
In response to the Staff’s comment, we have filed a representation letter as Exhibit 99.7 to the Amendment No. 1 with the required
statements pursuant to Instruction 2 of Item 8.A.4 of Form 20-F.
If you would like to discuss the response or if you would like to discuss
any other matters, please contact the undersigned at (852)3428-3893 or Kevin Sun of Bevilacqua PLLC at (202) 869-0888 (ext. 101).
Sincerely,
SOLOWIN HOLDINGS
By:
/s/ Shing Tak Tam
Name: Shing Tak Tam
Title: Chief Executive Officer
cc:
Kevin Sun, Esq., Bevilacqua PLLC
Michael J. Blankenship, Esq.,
Winston & Strawn LLP