SEC Comment Letter for ELC Group Holdings Ltd. (ELCG) (CIK 0002039096) — Aug 6, 2025
ELC Group Holdings Ltd. (ELCG) (CIK 0002039096)
Date: Aug. 6, 2025 · CIK: 0002039096 · Accession: 0000000000-25-008269
AI Filing Summary & Sentiment
File numbers found in text: 333-285524
Letter
August 6, 2025 Leann Koh Bee Khee Chief Executive Officer ELC Group Holdings Ltd. 745 Lor 5 Toa Payoh #03-02 The Lifeline Building Singapore 319455 Re:ELC Group Holdings Ltd. Amendment No. 4 to Registration Statement on Form F-1 Filed July 9, 2025 File No. 333-285524 Dear Leann Koh Bee Khee: We have reviewed your amended registration statement and have the following comment. 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. Amendment No. 4 to Registration Statement on Form F-1 General 1.Please update your financial statements, or file as an exhibit to the filing the necessary representations as to why such update is not necessary. Refer to Item 8.A.4 of Form 20-F and Instruction 2 thereto.
August 6, 2025 Page 2 Please contact Ta Tanisha Meadows at 202-551-3322 or Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters. Please contact Scott Anderegg at 202-551-3342 or Taylor Beech at 202-551-4515 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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August 6, 2025
Leann Koh Bee Khee
Chief Executive Officer
ELC Group Holdings Ltd.
745 Lor 5 Toa Payoh
#03-02 The Lifeline Building
Singapore 319455
Re:ELC Group Holdings Ltd.
Amendment No. 4 to Registration Statement on Form F-1
Filed July 9, 2025
File No. 333-285524
Dear Leann Koh Bee Khee:
We have reviewed your amended registration statement and have the following
comment.
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.
Amendment No. 4 to Registration Statement on Form F-1
General
1.Please update your financial statements, or file as an exhibit to the filing the necessary
representations as to why such update is not necessary. Refer to Item 8.A.4 of Form
20-F and Instruction 2 thereto.
August 6, 2025
Page 2
Please contact Ta Tanisha Meadows at 202-551-3322 or Joel Parker at 202-551-3651
if you have questions regarding comments on the financial statements and related
matters. Please contact Scott Anderegg at 202-551-3342 or Taylor Beech at 202-551-4515
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services