View:
United States securities and exchange commission logo
December 9, 2021
Ronald Tam
Co-Chief Financial Officer and Chief Strategy Officer
Huize Holding Limited
5/F, Building 3-4
Shenzhen Animation Park, Yuehai Road, Nanhai Avenue
Nanshan District, Shenzhen 518052, People s Republic of China
Re: Huize Holding
Limited
Form 20-F for the
Fiscal Year Ended December 31, 2020
Response dated
October 21, 2021
File No. 001-39216
Dear Mr. Tam:
We have reviewed your October 21, 2021 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
20, 2021 letter.
Form 20-F for the Fiscal Year Ended December 31, 2020
Item 3. Key Information, page 4
1. We note your response
to comment 4, including that control through your VIE contractual
arrangements may be
less effective than direct ownership, and that you could incur
substantial costs to
enforce the terms of the arrangements, because there are substantial
uncertainties regarding
the interpretation and application of current and future PRC laws,
regulations and rules
relating to these contractual arrangements. Please enhance your
disclosure to clarify,
if true, that the VIE contractual arrangements have not been tested in
a court of law.
Ronald Tam
FirstName LastNameRonald Tam
Huize Holding Limited
Comapany9,
December NameHuize
2021 Holding Limited
December
Page 2 9, 2021 Page 2
FirstName LastName
Item 3.D. Risk Factors, page 6
2. Please expand your risk factor disclosure to discuss that the United
States Senate passed
the Accelerating Holding Foreign Companies Accountable Act, which, if
enacted, would
decrease the number of non-inspection years from three years to two,
thus reducing the
time period before your securities may be prohibited from trading or
delisted. In addition,
please update your disclosure to reflect the SEC's adoption of the
amendments to finalize
the rules relating to the HFCAA.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Marc Thomas at 202-551-3452 or Robert Klein at
202-551-3847 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of
Finance