SEC Comment Letter 0000000000-24-010469 to HomesToLife Ltd (HTLM) (CIK 0002023153) (HTLM)
HomesToLife Ltd (HTLM) (CIK 0002023153)
Date: Sept. 16, 2024 · CIK: 0002023153 · Accession: 0000000000-24-010469
AI Filing Summary & Sentiment
File numbers found in text: 333-281693
Letter
September 16, 2024 Chew Kwang Yong Chief Financial Officer HomesToLife Ltd 6 Raffles Boulevard, #02-01/02 Marina Square, Singapore 039594 Re:HomesToLife Ltd Registration Statement on Form F-1 Filed August 22, 2024 File No. 333-281693 Dear Chew Kwang Yong: 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 July 31, 2024 letter. Registration Statement on Form F-1 Dilution, page 36 1.Please update your net tangible book value to December 31, 2023, as well as the underlying calculated amounts presented in the dilution table.
September 16, 2024 Page 2 Combined Financial Statements Combined Statements of Operations, page F-4 2.We reviewed the changes you made to correct the errors in your financial statements in response to prior comment 2. Please make arrangements with your auditor for them to revise their audit report to reference the error correction and the footnote that discusses it. Refer to paragraphs .09 and .16 of PCAOB AS 2820. Also, revise your financial statements to label them as restated and provide the disclosures required by ASC 250-10- 50-7, including disclosing the nature of the errors and quantifying the effect of the error correction on income from operations. Exhibit 5.1 3.Please revise to include counsel's consent to be named in the Material Income Tax Considerations section of the prospectus. Please contact Valeria Franks at 202-551-7705 or Rufus Decker at 202-551-3769 if you have questions regarding comments on the financial statements and related matters. Please contact Jenna Hough at 202-551-3063 or Lilyanna Peyser at 202-551-3222 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc:Jane Tam
Show Raw Text
September 16, 2024
Chew Kwang Yong
Chief Financial Officer
HomesToLife Ltd
6 Raffles Boulevard, #02-01/02
Marina Square, Singapore 039594
Re:HomesToLife Ltd
Registration Statement on Form F-1
Filed August 22, 2024
File No. 333-281693
Dear Chew Kwang Yong:
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 July 31, 2024 letter.
Registration Statement on Form F-1
Dilution, page 36
1.Please update your net tangible book value to December 31, 2023, as well as the
underlying calculated amounts presented in the dilution table.
September 16, 2024
Page 2
Combined Financial Statements
Combined Statements of Operations, page F-4
2.We reviewed the changes you made to correct the errors in your financial statements in
response to prior comment 2. Please make arrangements with your auditor for them to
revise their audit report to reference the error correction and the footnote that discusses
it. Refer to paragraphs .09 and .16 of PCAOB AS 2820. Also, revise your financial
statements to label them as restated and provide the disclosures required by ASC 250-10-
50-7, including disclosing the nature of the errors and quantifying the effect of the error
correction on income from operations.
Exhibit 5.1
3.Please revise to include counsel's consent to be named in the Material Income Tax
Considerations section of the prospectus.
Please contact Valeria Franks at 202-551-7705 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenna Hough at 202-551-3063 or Lilyanna Peyser at 202-551-3222 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Jane Tam