Mail Stop 4561 December 11, 2008
Jonathan Chesky Malamud
President and Chief Executive Officer
Map Financial Group, Inc.
460 West 34th Street, 10th Floor
New York, New York 10001
Re: Map Financial Group, Inc.
Registration Statement on Form S-1/A
Filed December 8, 2008
File No. 333-153726
Dear Mr. Malamud:
We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments. If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure. After
reviewing this information, we may raise additional comments.
Form S-1
Summary Consolidated Financial Information, page 3
1. We note that the share information for the seven months ended
July
31, 2008 and July 31, 2007 as well as the year ended December 31,
2006 does not agree with the information presented in the
financial
statements for the same periods. Please revise to present
consistent
information throughout the document.
Management`s Discussion and Analysis
Accounts Receivable, Loss History, Credit Quality and Aging of
Receivables, page 36
2. Please revise the disclosure on page 36 to report that 0.34%
and
0.80% of loans "issued" were written off during 2007 and 2006,
respectively.
3. You state that under the direct write-off method, accounts
receivable are written off and charged to income when they are
generally overdue by 120 days and all collection efforts have
failed.
On page 37 we note the $196,791 of receivables outstanding as of
December 2, 2008. Please tell and revise your disclosures to
explain
why you have such a significant balance of receivables greater
than
121 days considering you policy.
Financial Statements
4. Please note the updating requirements for the financial
statements
and related disclosures pursuant to Rule 3-12 of Regulation S-X.
Fast Cash International Ltd.
Statement of Income, page 2
5. We note that your net profit per share as of July 31, 2008 and
2007 is 44.65747 and 0.87518 respectively. Reverse mergers should
be
recorded when they are effected and must be retroactively
reflected
for the earlier balance sheets presented. Please revise your
financial statements accordingly.
Note 2 - Significant Accounting Policies, page 5
Direct Write-Off Method Used to Record Bad Debts, page 8
6. Based on your response to our prior comment 11, it appears you
are
utilizing the 0.57% loss percentage to the 2008, 2007 and 2006
allowance for bad debt balance determination. Please tell us why
you
did not consider industry, geographical and other data in
determining
your allowance. It is not clear to us that the direct write-off
method is not materially different from the results that would
have
been obtained under the allowance method. Please advise.
7. As a related matter, please update the notes to the December
31,
2007 financial statements to include the information requested in
our
prior comment 11.
Exhibit 23
8. Please provide a current consent of the independent accountant
in
any amendment.
* * * * *
As appropriate, please amend your registration statement in
response to these comments. You may wish to provide us with
marked
copies of the amendment to expedite our review. Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information. Detailed cover
letters greatly facilitate our review. Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment decision. Since the company and its
management are in possession of all facts relating to a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.
Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging 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.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.
We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.
We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement. Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration. Please provide this
request at least two business days in advance of the requested
effective date.
You may contact Babette Cooper, Staff Accountant at
(202)551-
3396 or Amit Pande, Assistant Chief Accountant at (202)551-3423 if
you have questions regarding comments on the financial statements
and
related matters. Please contact Allicia Lam at (202) 551-3316 or
me
at (202)551-3434 with any other questions.
Sincerely,
Michael R. Clampitt
Staff Attorney
cc: By fax (516) 887-8250
Michael Sufott
David Lubin & Associates, PLLC