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Re: andrewflying post# 136798

Wednesday, 05/02/2018 8:33:24 PM

Wednesday, May 02, 2018 8:33:24 PM

Post# of 163718
Anyone knows why the correspondence was published today a month late?
At the time the answer to an item I checked looked fine.The Sec commented in July2017:

Note 10. Accounts Receivable, page F-33
10. We note that there have been no bad debts during the three years presented in the financial statements and that you have determined that all amounts are collectible. We further note your analysis of collection on page 71. Please provide us with a more detailed analysis pursuant to ASC 310-10-35 as to why you did not record a bad debt reserve for receivables in the over 91 day categories for (1) Consulting and Service totaling CA, (2) Sales of Live Fish, eels and prawns (from Farms CA), and (3) Sales of Beef (QZH). In your response, please tell us the amounts of historical write-offs, if any, for the past three years. We may have further comment upon reviewing your response.

Then the company after including an impressive chart answered the following on 24Aug2017:

Accounts receivable comprised few customers. They are old customers and settled our debts punctually according to our credit terms as shown below in Ref. A. There were not any bad record for settlement and no historical write-offs for the past three years. According to our records, all accounts receivable over the 91-day category were fully settled in Q1 and Q2 2017.

Reference A—our credit terms

¨ For CA, Consulting and Services are within 120 days under normal conditions and for bigger and continuing projects are up to 365 days.

¨ For CA, Sale of Goods are within 90-days for normal wholesalers and distributors and for some large supermarket chain stores can be extended up to 120-days.

¨ For QZH, sales of beef are within 90-days and for some large supermarket chain stores can be extended up to 120-days.

Basically very punctual customers with whom they were comfortable to do business with like bankers without guarantees for Millions of Credit.Then the first $14M bombshell and now dilution for peanuts apparently because the old ‘punctual’ customers are punctual no more....I wonder if the Sec will be taking a second look at how the company answered to the above and other of their comments.
I hope Solomon has realized that you cannot act as banker in trade.Better to sell less or nothing at all than sell on credit without guarantees.

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