Monday, November 13, 2017 3:29:05 PM
SEC letter to Cemtrex dated March 18, 2014:
We note that you have not included Management’s Report on Internal Control over Financial Reporting, as required by Item 308 of Regulation S-K although your certifying officers indicate in their certifications that they performed the required evaluation of internal control over financial reporting as of September 30, 2013. Please amend your filing to provide Management’s Report on Internal Controls over Financial Reporting.
Cemtrex letter to SEC dated April 10, 2014:
The company's management is responsible for establishing and maintaining adequate "internal control over financial reporting" (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)). Management evaluates the effectiveness of the company's internal control over financial reporting using the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission (1992 framework). Management, under the supervision and with the participation of the company's Chief Executive Officer and Chief Financial Officer, assessed the effectiveness of the company's internal control over financial reporting as of September 30, 2013, and concluded that it is effective.
SEC letter to Cemtrex dated April 29, 2014:
We note your response to our prior comment 2. Please tell us whether you have reevaluated the fact that your disclosure controls and procedures and internal control over financial reporting remains effective considering your omission of Management’s Report of Internal Control over Financial Reporting. In this regard, please file the requested amendment.
Cemtrex letter to SEC dated May 28, 2014:
The company has re-evaluated its disclosure controls and procedures and internal control over financial reporting. The company has added a staff member with disclosure control and procedure experience and finds the company's internal control over financial reporting is effective. The amendment will be prepared and filed by June 13, 2014.
SEC letter to Cemtrex dated July 22, 2014:
We note your response to our prior comment 1. Please tell us how you were able to conclude that your disclosure controls and procedures and internal control over financial reporting remain, in fact, effective, considering your omission of Management’s Report of Internal Control over Financial Reporting and your omission of the financial statements required by Rule 8-04 of Regulation S-X. Please provide us with the basis for your conclusions or file an amendment to revise your conclusions accordingly.
Cemtrex letter to SEC dated August 5, 2014:
In regard to Item9A of our 10-K we maintain that while the wording of Management’s Report of Internal Control over Financial Reporting was accidentally omitted from the document our internal controls are effective and no material misstatements were made in regard to our financial statements or the accompanying notes. In regard to omission of the financial statements required by Rule 8-04 of Regulation S-X, this was not an issue in regards to our 10-K.
Cemtrex letter to SEC dated September 25, 2014:
We will file an amendment to our 10-K for September 30, 2013 indicating that our controls and procedures were ineffective.
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