China Yuchai International Limited
June 11, 2010
Via Edgar and Facsimile (703) 813-6985
Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549
United States
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Attention: |
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Brian Cascio
Gary Todd
Kristin Lochhead |
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Re: |
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China Yuchai International Limited
Form 20-F for Fiscal Year Ended December 31, 2009
Filed April 30, 2010
File No. 1-13522 |
This letter sets forth the response of China Yuchai International Limited (China Yuchai) to
the comment of the Staff of the Division of Corporation Finance of the Securities and Exchange
Commission (Commission) in its letter dated June 3, 2010, with respect to the above referenced
Form 20-F. For the Staffs convenience, the Staffs comment is set forth before China Yuchais
response.
1. Comment: We note that your independent registered accountants report does not
include an opinion on whether the financial statements comply with IFRS as issued by the IASB.
Please amend your filing to either provide an audit report that includes an opinion on whether
the financial statements comply with IFRS as issued by the IASB or please provide a
reconciliation from IFRS to US GAAP. Refer to Item 17(c) of Form 20-F. As a related matter,
please note that when you amend a filing, the entire text of the amended item must be included
in the amendment. Refer to Exchange Act Rule 12b-15.
Response to Comment:
China Yuchai respectfully submits that in response to the Staffs comment, China Yuchai has on
June 11, 2010 filed via Edgar Amendment No.1 on Form 20-F/A to its Annual Report on Form
20-F for the fiscal year ended December 31, 2009 (2009 Form 20-F), to file the revised audit
reports of the Companys independent registered public accounting
firm. The audit reports of the
Companys independent registered public accounting firm included
in the 2009 Form 20-F have been
revised solely to clarify that the Companys consolidated financial statements as of and for the
years ended December 31, 2008 and 2009 included in the previously filed 2009 Form 20-F have been
prepared in conformity with International Financial Reporting Standards as issued by the
International Accounting Standards Board.
As requested by the Staff, China Yuchai acknowledges the following:
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China Yuchai is responsible for the adequacy and accuracy of the disclosure in the
filing; |
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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 |
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China Yuchai 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. |
We believe that the above-mentioned filing of Amendment No. 1 to the 2009 Form 20-F fully
responds to the Staffs comment.
Please let me know if you have any further questions. I can be contacted at (65) 6322 6262 if I
can be of further assistance.
Yours sincerely
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/s/ Hoh Weng Ming |
Hoh Weng Ming
Chief Financial Officer |