0001078782-15-002068.txt : 20160122 0001078782-15-002068.hdr.sgml : 20160122 20151221210504 ACCESSION NUMBER: 0001078782-15-002068 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20151221 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SINO PAYMENTS, INC. CENTRAL INDEX KEY: 0001417664 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-MISCELLANEOUS BUSINESS SERVICES [7380] IRS NUMBER: 263767331 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 7/F, DARTON TOWER, 142 WAI YIP ST STREET 2: KWUN TONG CITY: KOWLOON STATE: K3 ZIP: NONE BUSINESS PHONE: 852 2950 4288 MAIL ADDRESS: STREET 1: 7/F, DARTON TOWER, 142 WAI YIP ST STREET 2: KWUN TONG CITY: KOWLOON STATE: K3 ZIP: NONE FORMER COMPANY: FORMER CONFORMED NAME: Sino Payments, Inc. DATE OF NAME CHANGE: 20081202 FORMER COMPANY: FORMER CONFORMED NAME: China Soaring Inc. DATE OF NAME CHANGE: 20071106 CORRESP 1 filename1.htm SEC Response Letter


SINO PAYMENTS, INC.

7/F, Darton Tower

142 WaiYip Street, Kwun Tong, Kowloon, Hong Kong

Telephone:  (852) 2950 4288


December 18, 2015


Celeste M. Murphy, Legal Branch Chief

William Mastrianna, Attorney-Adviser

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549


RE:

SINO PAYMENTS, INC.

SEC FILE#: 000-53537

RESPONSE TO SEC COMMENTS ON FORM 10-K ANNUAL REPORT FOR

FISCAL YEAR ENDED DECEMBER 31, 2014

BY FAX: EDGAR CORRESPOND/UPLOAD


Dear Ms. Murphy and Mr. Mastrianna:


This letter is the response to the Comment Letter, dated December 16, 2015, from the Securities and Exchange Commission (“SEC” or “Commission”) regarding the Form 10-K/A Amendment Number One by SINO Payments, Inc. for its fiscal year ended December 31, 2014.


Please contact our U.S. outside legal counsel, Paul W. Richter, at (804) 644-2182 (Richmond, Virginia) or at prosage@comcast.net with any questions or concerns, or with any further comments.  Thank you for your consideration in this matter.


1.  SEC COMMENT:


Exhibits


1.

We note on page 4 that you state that current dated certifications from your Chief Executive Officer and Chief Financial Officer have been included as exhibits to this amendment, but no exhibits are attached to the Form 10-K/A filed December 8, 2015. Please amend the 10-K/A to file certifications from your Chief Executive Officer and Chief Financial Officer.   


Issuer Response:  The exhibits for Amendment Number One (“Amendment”) to the Form 10-K Annual Report for the fiscal year ended December 31, 2014 were filed with Amendment Number 2 thereto and filed with the Commission on December 18, 2015.


The Company hereby acknowledges:


·

the Company is responsible for the adequacy and accuracy of the disclosure in the filing;


·

staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and


·

the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.


End of Company Response.


Sincerely,


/s/ Kenneth Tan


Kenneth Tan, Chief Executive Officer


cc:

PW Richter, PW Richter plc