CORRESP 1 filename1.htm

 

July 5, 2022

 

Via Edgar Transmission

 

Ms. Ibolya Ignat

Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

Washington, D.C. 20549

 

 

Re:

Agape ATP Corp (the “Company”)

Form 10-K for fiscal year ended December 31, 2021

Filed March 28, 2022

File No. 333-220144

 

Dear Ms. Ignat:

 

As counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated June 29, 2022 from the Securities and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced Form 10-K for fiscal year ended December 31, 2021 (the “Form 10-K”).

 

For the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set out immediately underneath such comment.

 

Form 10-K/A for fiscal year ended December 31, 2021

 

Item 9A. Controls and Procedures, page 39

 
1. We acknowledge the changes made in Item 9A of your amended Form 10-K and Item 4 of your amended Form 10-Q. However, these amended filings only address internal control over financial reporting and continue to omit your assessment and effectiveness conclusions for disclosure controls and procedures, as required by Item 307 of Regulation S-K. Accordingly, as originally requested, please amend your Form 10-K to include all of the information required by Item 307 of Regulation S-K and confirm that you will also provide this information in future Form 10-Q filings.

   
 

Response: We respectfully advise the Staff that we have revised Item 9A of the Form 10-K/A to include our assessment and effectiveness conclusions for disclosure controls and procedures. In additional, we have also updated Item 4 of the Form 10-Q/A for the nine months ended September 30, 2021 to include our assessment and effectiveness conclusions for disclosure controls and procedures. We confirm that we will also provide this information in future Form 10-Q filings.

 

* * *

 

 
 

 

Please contact the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.

 

Sincerely,

 

/s/ Lawrence S. Venick  
Lawrence S. Venick  
   
Direct Dial: +852.3923.1188  
Email: lvenick@loeb.com  

 

 
 

 

EXHIBIT A

 

Agape ATP Corporation

1705-1708, Level 17, Tower 2, Faber Towers

Jalan Desa Bahagia, Taman Desa
Kuala Lumpur, Malaysia

(Postal Code: 58100)

+(60) 192230099

 

July 5, 2022

 

In connection with its response to the United States Securities and Exchange Commission’s comment letter, dated June 29, 2022, Agape ATP Corporation (the “Company”) acknowledges the following:

 

  the Company is responsible for the adequacy and accuracy of the disclosure in the filing;
     
  Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and
     
  the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 

  AGAPE ATP CORPORATION
     
  By: /s/ How Kok Choong
    How Kok Choong
   

Chief Executive Officer,

Chief Operating Officer, Director, Chairman of the Board of Directors and Secretary

(Principal Executive Officer)