Cleartronic, Inc.
DBA ReadyOp Communications, Inc.
28050 US Hwy 19 N, Suite 310, Clearwater, FL 33761
Tel: 813-289-7620
April 28, 2023
By Electronic Submission
U.S. Securities and Exchange Commission
Division of Corporate Finance
Office of Technology
100 F Street, N.E.
Washington, DC 20549
Attention: Becky Chow
Stephen Krikorian
Re: Cleartronic, Inc.
Form 10-K for the fiscal year ended September 30, 2022
Filed December 29, 2022
File No. 000-55329
Dear Ms. Chow and Mr. Kirkorian:
We are in receipt of the comment letter, dated April 25, 2023, from the staff (the "Staff") of the Securities and Exchange Commission (the "SEC") regarding the above captioned filing on Form 10-K for the fiscal year ended September 30, 2022, filed on December 29, 2022 (the "Annual Report"). Below is the response of Cleartronic, Inc. ("Cleartronic," the "Company," "we," "our" or similar terminology) to the Staff's comments.
For the Staff's convenience, we have incorporated your comments into this response letter in italics. The Company acknowledges that it is responsible for the adequacy and accuracy of the disclosure in the Annual Report.
Form 10-K filed on December 29, 2022
Item9A. Controls and Procedures, page 9
1. 1. We noted your response to our comments 1 and 2 in our comment letter dated March 22, 2023. Please amend your Form 10-K to clearly disclose your management's conclusion of the assessment of your internal control over financial reporting as of September 30, 2022.
Our response to Comment #1:
We have filed an amendment to the Annual Report to disclose management's conclusion of the assessment of our internal control over financial reporting as of September 30, 2022, by making the changes proposed in our letter to the Staff dated March 27, 2023.
Should you have any questions or comments regarding our responses or if any additional or supplemental information is required by the Staff, please feel free to contact me at lreid@cleartronic.com - 954-826-2508.
Sincerely,
/s/ Larry M. Reid
Larry M. Reid
Chief Financial Officer