SEC Comment Letter for BOSTON CAPITAL TAX CREDIT FUND III L P (CIK 0000879555) — Jan 30, 2020
BOSTON CAPITAL TAX CREDIT FUND III L P (CIK 0000879555)
Date: Jan. 30, 2020 · CIK: 0000879555 · Accession: 0000000000-20-000794
AI Filing Summary & Sentiment
File numbers found in text: 000-21718
Letter
January 29, 2020 Marc N. Teal Chief Financial Officer Boston Capital Tax Credit Fund III LP One Boston Place, Suite 2100 Boston, MA 02108 Re:Boston Capital Tax Credit Fund III LP Form 10-K for the year ended March 31, 2019 Filed June 20, 2019 File No. 000-21718 Dear Mr. Teal: 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 10-K filed June 20, 2019 Item 9a. Controls and Procedures, page 34 1.In future filings, revise your disclosure to include a statement that the certifications of the Principal Executive Officer and Principal Financial Officer are applicable to each series as well as to the Fund. In addition, please tell us if management's conclusion on the effectiveness of internal control over financial reporting is applicable to each series individually, as well as the Fund as a whole, and clarify your conclusion in future filings. Exhibit 13 Report of Independent Registered Public Accounting Firm, page F-3 2.We note that the report of your independent auditor does not reference each series individually. Please have your auditor confirm to us that their report applies to the financial statements for each series individually. In future filings, the report should reference each series individually or separate reports should be provided for each
FirstName LastNameMarc N. Teal Comapany NameBoston Capital Tax Credit Fund III LP January 29, 2020 Page 2 FirstName LastName Marc N. Teal Boston Capital Tax Credit Fund III LP January 29, 2020 Page 2 series. Refer to Question 104.01 of the Securities Act Sections Compliance and Disclosure Interpretations. 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 Demarest at 202-551-3432 or Kristi Marrone at 202-551-3429 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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January 29, 2020
Marc N. Teal
Chief Financial Officer
Boston Capital Tax Credit Fund III LP
One Boston Place, Suite 2100
Boston, MA 02108
Re:Boston Capital Tax Credit Fund III LP
Form 10-K for the year ended March 31, 2019
Filed June 20, 2019
File No. 000-21718
Dear Mr. Teal:
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 10-K filed June 20, 2019
Item 9a. Controls and Procedures, page 34
1.In future filings, revise your disclosure to include a statement that the certifications of the
Principal Executive Officer and Principal Financial Officer are applicable to each series as
well as to the Fund. In addition, please tell us if management's conclusion on the
effectiveness of internal control over financial reporting is applicable to each series
individually, as well as the Fund as a whole, and clarify your conclusion in future filings.
Exhibit 13
Report of Independent Registered Public Accounting Firm, page F-3
2.We note that the report of your independent auditor does not reference each series
individually. Please have your auditor confirm to us that their report applies to
the financial statements for each series individually. In future filings, the report
should reference each series individually or separate reports should be provided for each
FirstName LastNameMarc N. Teal
Comapany NameBoston Capital Tax Credit Fund III LP
January 29, 2020 Page 2
FirstName LastName
Marc N. Teal
Boston Capital Tax Credit Fund III LP
January 29, 2020
Page 2
series. Refer to Question 104.01 of the Securities Act Sections Compliance and
Disclosure Interpretations.
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 Demarest at 202-551-3432 or Kristi Marrone at 202-551-3429
with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction