Correspondence 0001493152-24-036391 from Fast Track Group (FTRK) (CIK 0002027262) (FTRK)
Fast Track Group (FTRK) (CIK 0002027262)
Date: Sept. 16, 2024 · CIK: 0002027262 · Accession: 0001493152-24-036391
AI Filing Summary & Sentiment
File numbers found in text: 333-281969
Referenced dates: September 13, 2024
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CORRESP
1
filename1.htm
September
16, 2024
Via
Edgar Transmission
Mr.
Scott Anderegg / Mr. Donald Field
Securities
and Exchange Commission
Division
of Corporation Finance
Office
of Trade & Services
Washington,
D.C. 20549
Re:
Fast
Track Group
Registration
Statement on Form F-1
Filed
September 6, 2024
File
No. 333-281969
Dear
Mr. Anderegg /Mr. Field:
As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated September 13, 2024 from the
Securities and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”)
commented on the above-referenced Registration Statement on Form F-1 (the “Form F-1”).
For
the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set
out immediately underneath such comment.
Registration
Statement on Form F-1
Notes
to Consolidated Financial Statements
Note
2.1 Restatement of Consolidated Financial Statements, page F-13
1. We
note that you have restated your financial statements and footnote for the correction of
an error, but do not explain the original accounting for the transaction for the waiver of
debt from a related party. Please revise your disclosure to reflect a description of the
nature of the error that resulted in the restatement of capital contributions from a director.
Refer
to ASC 250-10-50-7.
Response:
The Company respectfully advises the Staff that the above has been updated on page F-13.
2. We
note that your financial statements are presented in Singapore Dollars (“S$”),
which is the reporting currency of the Company. Please revise the tabular reconciliation
of previously reported to restated amounts to present amounts in your reporting currency
rather than in US Dollars consistent with your other footnotes.
Response:
The Company respectfully advises the Staff that the previously reported amounts have been revised to address the above on page F-13.
Exhibit
5.1
Legal
Opinion, page II-4
3. We
note that you have not identified the number of shares to be registered. Please file a revised
opinion identifying the number of shares covered by the opinion. Additionally, please file
a revised opinion which provides the appropriate opinions for the offering of the underwriter
warrants and underlying shares. In this regard, we note that opinion paragraph 3 only covers
the shares to be offered in the initial public offering and does not cover the securities
being offered to the underwriter as compensation.
Response:
The Company respectfully advises the Staff that the above has been revised and has been included in the exhibits index.
Exhibit
23.1
Consent
of Independent Registered Public Accounting Firm, page II-4
4. Please
arrange to have your auditors revise their consent to properly refence to the dual dated
auditors report on July 8, 2024 except Note 2.1 for the Restatement of Consolidated Financial
Statements as to which the date is September 6, 2024.
Response:
The Company respectfully advise the Staff that the relevant consent has been included in the exhibits index.
*
* *
Please
contact the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.
Sincerely,
/s/
Lawrence S. Venick
Lawrence
S. Venick
Direct
Dial: +852.3923.1188
Email:
lvenick@loeb.com