SEC Comment Letter 0000000000-24-003873 to QMMM Holdings Ltd (QMMM)
QMMM Holdings Ltd
Date: April 10, 2024 · CIK: 0001971542 · Accession: 0000000000-24-003873
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-274887
Letter
United States securities and exchange commission logo April 10, 2024 Bun Kwai Chief Executive Officer QMMM Holdings Ltd Unit 1301, Block C, Sea View Estate, 8 Watson Road Tin Hau, Hong Kong Re:QMMM Holdings Ltd Amendment No. 2 to Registration Statement on Form F-1 Filed March 25, 2024 File No. 333-274887 Dear Bun Kwai: We have reviewed your amended registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our December 15, 2023 letter. Amendment No. 2 to Registration Statement on Form F-1 Cover Page 1.We note your response to prior comment 1 and reissue in part. Please revise your disclosure, as appropriate, to reflect the amount due to ManyMany Creation by the holding company for the payment of salaries of executive officers. In this regard, we note your Compensation of Directors and Executive Officers disclosure on page 79 and your Related Party disclosure on page 84 reflect expense for executive officer salaries of $181,787, whereas your cover page disclosure and page 4 of your prospectus summary disclosure reflect an amount of $45,773. Please reconcile.
FirstName LastNameBun Kwai Comapany NameQMMM Holdings Ltd April 10, 2024 Page 2 FirstName LastName Bun Kwai QMMM Holdings Ltd April 10, 2024 Page 2 Please contact Tony Watson at 202-551-3318 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 Dietrich King at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Jeffrey Li, Esq.
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United States securities and exchange commission logo
April 10, 2024
Bun Kwai
Chief Executive Officer
QMMM Holdings Ltd
Unit 1301, Block C, Sea View Estate,
8 Watson Road
Tin Hau, Hong Kong
Re:QMMM Holdings Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed March 25, 2024
File No. 333-274887
Dear Bun Kwai:
We have reviewed your amended registration statement and have the following
comment(s).
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our December 15, 2023 letter.
Amendment No. 2 to Registration Statement on Form F-1
Cover Page
1.We note your response to prior comment 1 and reissue in part. Please revise your
disclosure, as appropriate, to reflect the amount due to ManyMany Creation by the
holding company for the payment of salaries of executive officers. In this regard, we note
your Compensation of Directors and Executive Officers disclosure on page 79 and your
Related Party disclosure on page 84 reflect expense for executive officer salaries
of $181,787, whereas your cover page disclosure and page 4 of your prospectus summary
disclosure reflect an amount of $45,773. Please reconcile.
FirstName LastNameBun Kwai
Comapany NameQMMM Holdings Ltd
April 10, 2024 Page 2
FirstName LastName
Bun Kwai
QMMM Holdings Ltd
April 10, 2024
Page 2
Please contact Tony Watson at 202-551-3318 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 Dietrich King at 202-551-8071 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Jeffrey Li, Esq.