Creative Global Technology Holdings Ltd (CGTL) – Company response
2026-04-07 · Re: (the “Company”) Form 20-F for Fiscal Year Ended September 30, 2025 Filed on January 30, 2026 · Accession 0001213900-26-041002 · Agreed to revise
Responds to staff letter of 2026-03-30.
China-Based IssuersFiler Status & Cover PageIFRS & Foreign Private Issuers
2026-03-30 · Form 20-F for Fiscal Year Ended September 30, 2025 · Comment 1 · General Agreed to revise
Staff comment: Please revise future filings, as applicable, to provide more specific and prominent disclosures about the legal and operational risks associated with China-based companies. For additional guidance, please see the Division of Corporation Finance’s Sample Letter to China-Based Companies issued by the Staff in December 2021 (the "CBI Sample Letter"). To the extent the CBI Sample Letter requests disclosure on the prospectus cover page or in the prospectus summary, please provide such disclosure in a separate section at the beginning of Item 3 of Form 20-F; in addition, please include a discussion of the transfer of cash within the company in Item 5 of Form 20-F. letter →
Company response: to the Staff’s comment, the Company will revise future filings, as applicable, to provide more specific and prominent disclosures about the legal and operational risks associated with China-based companies. To the extent the CBI Sample Letter requests disclosure on the prospectus cover page or in the prospectus summary, the Company will provide such disclosure in a separate section at the beginning of Item 3 of Form 20-F; in addition, the Company will include a discussion of the transfer of cash within the Company in Item 5 of Form 20-F. response letter →
Full letter on EDGAR → · Filing index · All Creative Global Technology Holdings Ltd (CGTL) correspondence
China-Based Issuers – what to check: Address PRC regulatory, VIE structure, cash transfer and HFCAA disclosures prominently up front.
Filer Status & Cover Page – what to check:
IFRS & Foreign Private Issuers – what to check:
Templates & resources
- AICPA & CIMA – SEC reporting resources (AICPA & CIMA · Professional body · Free / member)
- BDO Accounting, Reporting & Compliance Hub (ARCH) (BDO · Firm guide · Free)
- Deloitte DART – Roadmap Series (Deloitte · Firm guide · Free)
- Deloitte Roadmap: SEC Comment Letter Considerations (Deloitte · Firm guide · Free)
- KPMG Financial Reporting View (KPMG · Firm guide · Free)
- PwC Viewpoint (PwC · Firm guide · Free / paid)
- RSM Financial Reporting Resource Center (RSM · Firm guide · Free)
- SEC – EDGAR Full Text Search (SEC · Regulator · Free)