United States securities and exchange commission logo
April 28, 2022
Srikumar Vanamali
Chief Executive Officer
GEX Management, Inc.
662 W. Camp Wisdom Road
Dallas, Texas 75237
Re: GEX Management,
Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed April 15,
2021
Amendment No. 3 to
Form 10-K for the Fiscal Year Ended December 31, 2020
Filed February 11,
2022
Amendment No 1.Form
10-Q for the Period Ended June 30, 2021
Filed February 8,
2022
File No. 001-38288
Dear Mr. Vanamali:
We have reviewed your March 8, 2022 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
December 2, 2021 letter.
Srikumar Vanamali
FirstName LastNameSrikumar Vanamali
GEX Management, Inc.
Comapany
April NameGEX Management, Inc.
28, 2022
April 228, 2022 Page 2
Page
FirstName LastName
Amendment No 1.Form 10-Q for the Period Ended June 30, 2021
Notes to the Condensed Consolidated Financial Statements, page 8
1. We note your response to our prior comment number 3. It is not clear
why the obligations
for your "merchant cash advances" that are material to you and in
default are not
discussed in the notes to your financial statements in all periodic
filings until they are
either satisfied or no longer considered material in your
circumstances. It appears
disclosure in the notes to the financial statements commensurate with
your response, along
with all material terms and conditions, including any associated
defaults and related
consequences and status of settlement discussions, would be useful
information to
investors and support associated amounts reported in your financial
statements. Please
advise and revise as appropriate.
Amendment No. 3 to Form 10-K for the Fiscal Year Ended December 31, 2020
Item 9A. Controls and Procedures
Conclusions Related to Internal Control over Financial Reporting, page 12
2. You have revised your disclosure in this section to repeat your
conclusion regarding the
effectiveness of your disclosure controls and procedures rather than
disclose your
conclusion in regard to your internal controls over financial
reporting. Please note that a
conclusion regarding the effectiveness of your internal controls over
financial reporting is
required by Item 308(a)(3) of Regulation S-K apart from a conclusion
regarding
disclosure controls and procedures required by Item 307 of Regulation
S-K. Please revise
as appropriate.
You may contact Aamira Chaudhry at 202-551-3389 or Doug Jones at
202-551-3309 if
you have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of
Corporation Finance
Office of Trade
& Services