DT Asia Investments Limited
Room 703, 7/F.,
Beautiful Group Tower,
77 Connaught Road Central, Hong Kong
(852) 2110-0081
VIA EDGAR
June 20, 2016
U.S. Securities and Exchange Commission
Office of Financial Services
100 F Street, N.E.
Mail Stop 4720
Washington, DC 20549
Attn: Christian N. Windsor, Special Counsel
RE: | DT Asia Investments Limited |
Revised Preliminary Proxy Statement on Schedule 14A
Filed June 8, 2016
File No. 001-36664
Dear Mr. Windsor:
DT Asia Investments Limited (the “Company”, “it”, “we”, “us” or “our”), pursuant to conversations with the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), hereby supplements and transmits its response to the letter received by us from the Staff of the Commission dated June 13, 2016 and responded to on June 15, 2016 and June 17, 2016 regarding our Amendment No. 2 to our Preliminary Proxy Statement on Schedule 14A (the “Proxy Statement”) previously filed on June 8, 2016. Select pages of the Proxy Statement are enclosed asExhibit A herewith showing our proposed changes to the Proxy Statement in response to our discussion with the Staff on June 20, 2016.
For your convenience, we have summarized below the Staff’s oral comments in bold and have followed each comment with the Company’s response.
Risk Factors, page 36
China Lending Group uses credit reports issued by the Credit Reference Center of the People’s Bank of China for credit records, which may not cover all accurate credit activities of guarantors and borrowers, page 41
1. | Please add disclosure, if appropriate, to address China Lending Group’s difficulties in obtaining accurate credit information and in proceeding against privately-owned guarantors. |
In response to the Staff’s comment, we have revised the disclosure on page 41 of the Proxy Statement.
Christian N. Windsor, Special Counsel
U.S. Securities and Exchange Commission
June 20, 2016
Page 2
China Lending Group Management's Discussion and Analyses of Financial Condition and Results of Operations, page 179
Allowance for Loan Losses, page 185
2. | With respect to the sentence on Page 186 describing the 1% general reserve as suggested by the PBOC guidance as reasonably reflective of the future risk in loan losses with the region, please revise your disclosure to indicate that the PBOC guidance is reasonably reflective of “incurred” risk in loan losses within the region. |
In response to the Staff’s comment, we have revised the disclosure on page 186 of the Proxy Statement.
Notes to the Unaudited Consolidated Financial Statements of Adrie Global Holdings Limited, page F-58
Note 6 - Loan Impairment, page F-72
3. | Please characterize and describe in greater detail what “new information” the Company obtained on the trouble debt restructuring loans that the Company obtained during the first three months of 2016. |
In response to the Staff’s comment, we have revised the disclosure on page F-72 of the Proxy Statement.
We thank the Staff for its review of the foregoing. If you have further comments, we ask that you forward them by electronic mail to our counsel, Stuart Neuhauser at sneuhauser@egsllp.com or by telephone at (212) 370-1300.
Very truly yours, | |
/s/ Stephen N. Cannon | |
Stephen N. Cannon President and Chief Executive Officer |
cc: | Stuart Neuhauser, Esq. |
Ellenoff Grossman & Schole LLP |
Exhibit A
Proposed Changes to Proxy Statement