[QMIS TBS CAPITAL GROUP LETTERHEAD]
April 27, 2021
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: |
| Julia Griffith |
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| J. Nolan McWilliams |
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| Michael Volley |
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| Amit Pande |
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Re: |
| QMIS TBS Capital Group Corp. |
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| Registration Statement on Form S-1 |
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| Originally Filed June 2, 2020 |
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| File No. 333-238872 |
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| REQUEST FOR ACCELERATION OF EFFECTIVENESS |
Dear Ms. Griffith, Mr. McWilliams, Mr. Volley, and Mr. Pande:
On February 1, 2021, Ms. Griffith called Park Lloyd of Kirton McConkie, P.C., counsel to the Company, to let him know that the Commission had no further comments on the Registration Statement referenced above, SEC File No. 333-238872 (the “Registration Statement”), of QMIS TBS Capital Group Corp. (the “Company”).
The Company has filed today Amendment No. 3 to the Registration Statement, solely to provide updated audited financial statements for the Company for the year ended December 31, 2020, as well as audited financial statements of the Company’s subsidiary/related company, Richfield Orion International, Inc., for the year ended December 31, 2020, as well as to update the Management’s Discussion and Analysis section and other sections of the Registration Statement related to the financial statements. No other substantive changes have been made to the Registration Statement, and there are no changes to the transaction described therein.
Accordingly, based on Ms. Griffith’s notification of no additional comments by the Commission, and pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the Company hereby requests acceleration of the effective date of the above-referenced Registration Statement, so that it may become effective at 10:00 a.m. Eastern Standard Time on Friday, April 30, 2021, or as soon thereafter as possible.
The undersigned acknowledges, on behalf of the Company, that:
-should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
-the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
-the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
We request that we be notified of such effectiveness by a telephone call to company counsel, C. Parkinson Lloyd of Kirton McConkie at (801) 350-7619, and that such effectiveness also be confirmed in writing.
Thank you for your consideration and assistance in this matter.
Respectfully submitted,
QMIS TBS CAPITAL GROUP CORP. |
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/s/ Timo Bernd Strattner |
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Dr. Timo Bernd Strattner, CFO |
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