SEC Comment Letter 0000000000-23-012834 to Joint Stock Co Kaspi.kz (KSPI)
Joint Stock Co Kaspi.kz
Date: Nov. 24, 2023 · CIK: 0001985487 · Accession: 0000000000-23-012834
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Letter
United States securities and exchange commission logo November 24, 2023 Mikheil Lomtadze Chief Executive Officer Joint Stock Co Kaspi.kz 154A Nauryzbay Batyr Street Almaty, 050013, Kazakhstan Re:Joint Stock Co Kaspi.kz Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted November 9, 2023 CIK No. 0001985487 Dear Mikheil Lomtadze: We have reviewed your amended draft registration statement and have the following comment. 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 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 the information you provide in response to this letter and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 1 to Draft Registration Statement on Form F-1 General 1.Please supplementally provide us with the Level III ADS Deposit Agreement. Please also confirm that you will file the March 28, 2019 GDR Deposit Agreement with your Form F- 6. Please see Item 3(c) of Form F-6.
FirstName LastNameMikheil Lomtadze Comapany NameJoint Stock Co Kaspi.kz November 24, 2023 Page 2 FirstName LastName Mikheil Lomtadze Joint Stock Co Kaspi.kz November 24, 2023 Page 2 Please contact Ryan Rohn at 202-551-3739 or Stephen Krikorian at 202-551-3488 if you have questions regarding comments on the financial statements and related matters. Please contact Aliya Ishmukhamedova at 202-551-7519 or Jan Woo at 202-551-3453 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Nicholas P. Pellicani
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United States securities and exchange commission logo
November 24, 2023
Mikheil Lomtadze
Chief Executive Officer
Joint Stock Co Kaspi.kz
154A Nauryzbay Batyr Street
Almaty, 050013, Kazakhstan
Re:Joint Stock Co Kaspi.kz
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted November 9, 2023
CIK No. 0001985487
Dear Mikheil Lomtadze:
We have reviewed your amended draft registration statement and have the following
comment.
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 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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Amendment No. 1 to Draft Registration Statement on Form F-1
General
1.Please supplementally provide us with the Level III ADS Deposit Agreement. Please also
confirm that you will file the March 28, 2019 GDR Deposit Agreement with your Form F-
6. Please see Item 3(c) of Form F-6.
FirstName LastNameMikheil Lomtadze
Comapany NameJoint Stock Co Kaspi.kz
November 24, 2023 Page 2
FirstName LastName
Mikheil Lomtadze
Joint Stock Co Kaspi.kz
November 24, 2023
Page 2
Please contact Ryan Rohn at 202-551-3739 or Stephen Krikorian at 202-551-3488 if you
have questions regarding comments on the financial statements and related matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Jan Woo at 202-551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Nicholas P. Pellicani