November 8, 2019
Jason Wang
Chief Financial Officer
Fincera Inc.
27/F, Kaiyuan Finance Center, No. 5, East Main Street
Shijiazhuang, Hebei
People's Republic of China
Re: Fincera Inc.
Amendment No. 1 to Form 20-F for the Fiscal Year Ended December 31,
2018
Response Dated October 10, 2019
File No. 001-34477
Dear Mr. Wang:
We have reviewed your October 10, 2019 response to our comment letter
and have the
following comments. In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.
Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in
our September 10, 2019 letter.
Amendment No. 1 to Form 20-F for the Fiscal Year Ended December 31, 2018
Consolidated Balance Sheets, page F-2
1. We note from your response to comment 6 that your Loans, Net amounts
reported at
December 31, 2018 and 2017 include loans that you intended to sell.
Please explain how
your accounting treatment, presentation, and related disclosures for the
loans you intended
to sell is consistent with ASC 310-10 (loans held for sale). In addition,
for those those
loans that you did not intend to sell (including non-performing loans),
if any, explain how
you considered ASC 310-30 in your accounting treatment. Please advise or
revise as
necessary.
2. We also note from your disclosure on page F-25 that your other financing
receivables, net
were sold to CeraVest investors after July 2017. Similar to our comment
above, please
Jason Wang
Fincera Inc.
November 8, 2019
Page 2
explain how your accounting treatment, presentation, and related
disclosures for the other
financing receivables that you intended to sell was consistent with
ASC 310-10 (loans
held for sale) and ASC 860 Transfers and Servicing.
Notes to the Consolidated Financial Statements
Note 5 - Loans, Net, page F-23
3. We note from your response to comment 7 and your disclosure on pages
35 and 36
that the CeraVest loan portfolio includes three separate and distinct
loan categories (i.e.,
Quinying (30-day lines of credit), Yueying (180-day term loans), and
Zhongying
(installment loans). Please revise your future filings here and
elsewhere, as applicable
(e.g., on pages F-25 (Note 6 - Other Financing Receivables, Net) and
F-26 (Note 7 -
Long-Term Loans, Net)) to disaggregate your ASC 310 disclosures (i.e.,
loan disclosures,
allowance for loan loss disclosures, and troubled debt restructuring
disclosures) and
provide this information at a more granular level.
4. We note your response to comment 8. Please revise your disclosure in
future filings (e.g.,
at the bottom of page F-24) to clearly label those loans under ASC
310-40 and the related
disclosures as troubled debt restructurings.
5. We note your response to comment 9 and that you determined a guaranty
liability under
ASC 460 was not required for those loans sold to investors on your P2P
platform in 2017.
However, it is not clear from your response how you determined it was
appropriate under
U.S. GAAP to reclassify the related provision (i.e., allowance for
loan losses) to accrued
marketing costs after the loans were sold. In addition, regarding the
sale of loans, tell us
what consideration you gave to the applicability of ASC 860 Transfers
and Servicing and
provide us with your accounting analysis. Please advise or revise as
necessary.
You may contact Robert Klein, Staff Accountant, at 202-551-3847 or Hugh
West,
Accounting Branch Chief, at 202-551-3872 with any questions.
FirstName LastNameJason Wang Sincerely,
Comapany NameFincera Inc.
Division of
Corporation Finance
November 8, 2019 Page 2 Office of
Finance
FirstName LastName