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United States securities and exchange commission logo
March 17, 2021
Hu Anlin
Director, Chief Financial Officer and Vice President
PUYI, Inc.
42F, Pearl River Tower
No. 15 Zhujiang West Road, Zhujiang New Town, Tianhe, Guangzhou
Guangdong Province, People s Republic of China
Re: PUYI, Inc.
Form 20-F
Filed September 28,
2020
File No. 001-38813
Dear Mr. Anlin:
We have limited our review of your filing to the financial
statements and related
disclosures 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.
Form 20-F filed September 28, 2020
B. Business Overview
Asset Management Services, page 34
1. Please provide us with,
and revise future filings to include, an enhanced description of the
five NPL funds under
your management accompanied by a relevant discussion of how
management fees are
determined and quantification of the fund balances and total revenue
associated with these
funds for each period presented.
2. We note that your
rollforward of FoF fund units under your asset management services as
presented on page 36
reflects a balance of RMB 484.9 million and RMB 663.1 million as
of July 1, 2019 and
June 30, 2020, respectively. Please describe for us, and revise future
filings to explain, the
difference between the beginning and ending balances in the
rollforward compared to
the disclosure on pages 36, 60 and 72 stating that AUM totaled
Hu Anlin
FirstName
PUYI, Inc. LastNameHu Anlin
Comapany
March NamePUYI, Inc.
17, 2021
March2 17, 2021 Page 2
Page
FirstName LastName
RMB 502.8 million and RMB 849.0 million as of July 1, 2019 and June
30, 2020,
respectively.
3. Please provide us with, and revise future filings to include, an
evolution of total AUM for
a holistic rollforward view in addition to any disaggregated view you
currently provide.
4. We note your disclosure on page 36 that the increase in AUM was
primarily due to certain
factors including fair value changes in funds due to their positive
performance. In future
filings, please quantify the fair value changes by fund unit in your
AUM roll forward and
/or in the relevant discussion describing the underlying reasons for
the fluctuation in
AUM.
Item 5. Operating and Financial Review Prospects
Results of Operations
Operating Costs and Expenses, page 72
5. Please explain for us, and revise future filings to discuss in detail,
the specific facts and
circumstances driving the increase in the allowance for doubtful
accounts during the year
ended June 30, 2020 (e.g., age of amounts due, payment history,
creditworthiness,
financial conditions of the product providers and industry trends).
Please be as specific
and detailed as needed in order to provide a clear understanding of
the changes, or trends,
in credit quality driving the current year provision and the effect on
each component of the
allowance for doubtful accounts.
6. Please revise future filings to include a rollforward of activity for
the allowance for
doubtful accounts (e.g., charge-offs, recoveries, provision, etc.) for
each period presented.
Consolidated Statements of Financial Position, page F-3
7. Please tell us, and revise future filings to disclose on the face of
the balance sheet, the
carrying amount and classification of the VIE assets and liabilities
ensuring that these
amounts reconcile to your footnote disclosure on page F-14. Refer to
ASC 810-10-45-25.
Notes to Consolidated Financial Statements
Note 1. Organizational and Principal Activities, page F-14
8. We note your disclosure on pages 96 and F-14 that total assets and
liabilities presented on
the consolidated balance sheets and sales, expense, net income
presented on the
consolidated statement of income (loss) as well as the cash flow from
operating, investing
and financing activities presented on the consolidated statement of
cash flows are
substantially the financial position, operation and cash flow of the
Company s VIE Puyi
Bohiu and its subsidiaries. While this appears accurate for the years
ended June 30, 2018
and 2019, there are significant differences between the amounts
reported as total assets,
total liabilities, net revenues and net income for the year ended June
30, 2020. Please tell
us, and revise future filings to explain, the underlying reasons for
these differences. Your
enhanced disclosures should allow a reader to reconcile between the
financial statement
Hu Anlin
PUYI, Inc.
March 17, 2021
Page 3
and footnote disclosures, using qualitative and quantitative
information, and to understand
any changes in presentation compared to prior periods.
Note 13. Other, net, page F-34
9. Please provide us with, and revise future filings to include, an
enhanced understanding of
the nature and purpose of government grants that were recognized as
other income and the
underlying reasons for the increase in grants during the year ended
June 30, 2020.
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 William Schroeder, Staff Accountant, at 202-551-3294 or
Ben Phippen,
Staff Accountant, at 202-551-3697 with any questions.
FirstName LastNameHu Anlin Sincerely,
Comapany NamePUYI, Inc.
Division of
Corporation Finance
March 17, 2021 Page 3 Office of Finance
FirstName LastName