Waton Financial Ltd (WTF)
CIK 1987363 · EDGAR correspondence
| Date | Company | Type | Outcome | Issues |
|---|---|---|---|---|
| 2026-04-07 | Waton Financial Ltd (WTF) | SEC staff letter | Review completed (no further comments) | |
| 2026-03-30 | Waton Financial Ltd (WTF) | Company response | Agreed to revise | Non-GAAP: Adjustments & LabelsNon-GAAP: Reconciliation & UsefulnessGoodwill & Asset ImpairmentFair Value & InvestmentsBusiness Description (Item 101) |
| 2026-03-24 | Waton Financial Ltd (WTF) | SEC staff letter | 2 staff comment(s) issued | Non-GAAP: Adjustments & LabelsNon-GAAP: Reconciliation & UsefulnessGoodwill & Asset ImpairmentFair Value & InvestmentsBusiness Description (Item 101) |
Comments & responses
2026-03-24 · Waton Financial Limited Form 20-F for Fiscal Year Ended March 31, 2025 · Comment 1 · B. Business Overview, page 44 Agreed to revise
Staff comment: We note your disclosure of the non-GAAP financial measures 'Adjusted Net Income' and 'Adjusted Net Loss' in your business overview on page 45 when discussing results of operations in the periods presented. Please represent to us that, in future filings, you will provide all the non-GAAP disclosures required by Item 10(e)(1)(i) of Regulation S-K. letter →
Company response: The Company acknowledges the Staff’s comment. In future filings, the Company will provide all of the disclosures required by Item 10(e)(1)(i) of Regulation S-K with respect to any non-GAAP financial measures presented. response letter →
2026-03-24 · Waton Financial Limited Form 20-F for Fiscal Year Ended March 31, 2025 · Comment 2 · (n) Investment, cost, page F-11 Agreed to revise
Staff comment: We note that you assess impairment of your equity investment without a readily determinable fair value using an other-than-temporary model. We also note that ASU 2016-01 removed this model for these equity security investments to apply a one-step approach as explained further in paragraphs BC85 to BC89 of that ASU. As a result, please address the following: • Tell us whether your $618,630 impairment recorded in fiscal 2025 would have been larger or whether you would have recorded any impairment in fiscal 2024 if, instead of apply an other-than-temporary model, you employed a direct assessment of fair value to carrying value if indicators of impairment existed. If so, demonstrate to us… letter →
Company response: The Company acknowledges the Staff’s comment. The Company’s equity investment, without a readily determinable fair value, is the less-than-1% ownership interest in New Markets (BVI) Limited (Microconnect), which is accounted for in accordance with ASC 321-10-35-2, 35-3, and 35-4, instead of the “other than temporary” method mentioned in Note 2(n) of the consolidated financial statements of the Company for the years ended March 31, 2025 and 2024. Specifically, the Company performed a qualitative assessment for impairment indicators according to ASC 321-10-35-3 as of March 31, 2025 and 2024, respectively. The Company identified impairment indicators, including significant operating losses and… response letter →
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