Filer Status & Cover Page
What to check in your filing: Review recent comments below against your own disclosure.
7 staff comments from 7 companies. Outcomes: Agreed to revise: 4, Awaiting / response not in dataset: 3
Creative Global Technology Holdings Ltd (CGTL) · 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 →
LSI INDUSTRIES INC (LYTS) · 2026-02-27 · LSI Industries, Inc. Form 10-K for the Year Ended June 30, 2025 Filed September 11, 2025 · Comment 1 · General, page 30 Agreed to revise
Staff comment: We note that you have indicated on the cover page that you are an accelerated filer and your public float at December 31, 2024 was $580,496,057. Please tell us why you have only included two years of financial statements in your Form 10-K. Refer to Rules 3-01 and 3-02 of Regulation S-X. letter →
Company response: We acknowledge your comment and direction and recognize that smaller reporting company scaled disclosure alternatives were not applicable to our Form 10-K. The third year financial statement information is publicly available in our prior year Form 10-K and we confirm there have been no changes to that information. We will include three years of financial statements in our upcoming Form 10-K for the fiscal year ended June 30, 2026 in compliance with Rules 3-01 and 3-02 of Regulation S-X. response letter →
XChange TEC.INC (XHG) · 2026-02-04 · Amendment No 1. to Registration Statement on Form F-3 Filed October 29, 2025 · Comment 4 · require shareholder approval or registration under Rule 145 of the Securities Act. Awaiting / response not in dataset
Staff comment: Based on your response to our prior comment 1 to our letter dated September 17, 2025, it appears that you have sold 25,770,000 ADSs since December 2023. Please provide us with detailed legal analysis as to your Form F-3 eligibility at each of the three takedowns in 2024 and 2025. Please clarify how you concluded that you were eligible to sell 13.9 million ADSs on December 19, 2024, 2 million ADSs on March 18, 2025 and 9.87 million ADSs on April 18, 2025. Please be detailed as to what your public float was at each of the referenced takedowns and detail the timeliness of all applicable updates to your financial statements. letter →
Accordant ODCE Index Fund · 2026-01-16 · (the “Registrant”) · Comment 23 · Comment Agreed to revise
Staff comment: Please remove the delaying amendment language on the cover page from future filings. letter →
Company response: 23 . The Registrant will remove the “delaying amendment” language from the cover page. response letter →
Kuber Resources Corp (KUBR) · 2025-12-15 · Form 10-K for the Fiscal Year Ended December 31, 2024 Form 10-Q for the Quarterly Period Ended September 30, 2025 · Comment 3 · General Agreed to revise
Staff comment: Please revise to provide the disclosures in the Division of Corporation Finance’s Sample Letter to China-Based Companies issued by the Staff in December 2021. To the extent that the letter requests disclosure on the prospectus cover page or in the prospectus summary, please provide these disclosures in the forepart of your Form 10- K. letter →
Company response: The Company proposes to add, in the forepart of future filings, tailored disclosures responsive to the Division of Corporation Finance's Sample Letter to China-Based Companies (December 2021), including as applicable to the Company: 1. A statement in the forepart disclosing clearly that the Company is not a Chinese or Hong Kong operating company but a U.S. holding company incorporated in the State of Nevada as a holding company with no material operations of its own; and that the Company conducts a substantial majority of its operations through its wholly owned operating entities established in the PRC and in Hong Kong, and not through a VIE structure. We will include risks to our… response letter →
Lanvin Group Holdings Ltd (LANV, LANWF) · 2025-11-28 · Lanvin Group Holdings Limited Form 20-F Filed on April 30, 2025 · Comment 1 · page 44 Awaiting / response not in dataset
Staff comment: We note you disclose that you qualify as an emerging growth company (“EGC”) and have elected not to opt out of the extended transition period for complying with new or revised accounting standards. Please be advised that the EGC accounting deferral election is not applicable to IFRS filers and revise your disclosures accordingly in future filings. The Company respectfully acknowledges the Staff’s comment. The Company, as an EGC, prepares its financial statements in accordance with International Financial Reporting Standards (“ IFRS ”) as issued by the International Accounting Standards Board and, as an IFRS filer, is not eligible to elect the extended transition period for complying with… letter →
Dogness (International) Corp (DOGZ) · 2025-11-24 · · Comment 2 · Cover Page Awaiting / response not in dataset
Staff comment: Your registration statement indicates this is an offering for up to $300,000,000. However, on page 1 you state it is an offering for up to $250,000,000. Please reconcile. letter →
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