SEC Company Response from 1st FRANKLIN FINANCIAL CORP (CIK 0000038723) — Apr 20, 2020
1st FRANKLIN FINANCIAL CORP (CIK 0000038723)
Date: April 20, 2020 · CIK: 0000038723 · Accession: 0000038723-20-000034
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File numbers found in text: 333-237643
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CORRESP 1 filename1.htm ** 1st Franklin Financial Corporation April 20, 2020 Via EDGAR Donald Field Office of Finance Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-3628 Re: 1st Franklin Financial Corporation Registration Statement on Form S-1 File No. 333-237643 Dear Mr. Field: In accordance with Rule 461 of the General Rules and Regulations of the Securities Act of 1933, 1st Franklin Financial Corporation (the “Company”) hereby requests that the effective time and date of the Company’s Registration Statement on Form S-1 (File No. 333-237643) (the “Registration Statement”) be accelerated to 4:00 p.m., Eastern time, on April 21, 2020 or as soon as practicable thereafter. Once the Registration Statement has been declared effective, we respectfully request that you confirm that event with our counsel, Mark L. Hanson of Jones Day, at (404) 581-8573. Please contact Mark L. Hanson at Jones Day at (404) 581-8573 if you have any questions concerning the foregoing. Thank you for your attention to this matter. Very truly yours, 1st Franklin Financial Corporation /s/ A. Roger Guimond By: A. Roger Guimond Title: Executive Vice President and Chief Financial Officer NAI-1512811233v1