SEC Comment Letter 0000000000-25-010165 to APEX Global Solutions Ltd (APEX) (CIK 0002069858)
APEX Global Solutions Ltd (APEX) (CIK 0002069858)
Date: Sept. 18, 2025 · CIK: 0002069858 · Accession: 0000000000-25-010165
AI Filing Summary & Sentiment
File numbers found in text: 333-289708
Letter
September 18, 2025 Goh Kwang Yong Chief Executive Officer APEX Global Solutions Ltd 1 Tuas View Place, #03-14 Westlink One Singapore 637433 Re:APEX Global Solutions Ltd Amendment No. 1 to Registration Statement on Form F-1 Filed September 8, 2025 File No. 333-289708 Dear Goh Kwang Yong: 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. 1 to Registration Statement on Form F-1 filed September 8, 2025 Report of Independent Registered Public Accounting Firm, page F-2 1.We note from your disclosure on page F-7 that the financial statements have been retroactively adjusted to reflect the voluntary surrender of the Class A and Class B ordinary shares by your shareholders on September 4, 2025 and the subsequent retirement of such shares. Given the retrospective presentation of the share reorganization in the historical financial statements, please request that your independent auditor provide you with a dual-dated or re-dated audit report as well as an updated consent to reflect the revised audit report.
September 18, 2025 Page 2 Please contact SiSi Cheng at 202-551-5004 or Andrew Blume at 202-551-3254 if you have questions regarding comments on the financial statements and related matters. Please contact Eranga Dias at 202-551-8107 or Erin Purnell at 202-551-3454 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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September 18, 2025
Goh Kwang Yong
Chief Executive Officer
APEX Global Solutions Ltd
1 Tuas View Place, #03-14
Westlink One
Singapore 637433
Re:APEX Global Solutions Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed September 8, 2025
File No. 333-289708
Dear Goh Kwang Yong:
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. 1 to Registration Statement on Form F-1 filed September 8, 2025
Report of Independent Registered Public Accounting Firm, page F-2
1.We note from your disclosure on page F-7 that the financial statements have been
retroactively adjusted to reflect the voluntary surrender of the Class A and Class B
ordinary shares by your shareholders on September 4, 2025 and the subsequent
retirement of such shares. Given the retrospective presentation of the share
reorganization in the historical financial statements, please request that your
independent auditor provide you with a dual-dated or re-dated audit report as well as
an updated consent to reflect the revised audit report.
September 18, 2025
Page 2
Please contact SiSi Cheng at 202-551-5004 or Andrew Blume at 202-551-3254 if you
have questions regarding comments on the financial statements and related matters. Please
contact Eranga Dias at 202-551-8107 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing