SEC Comment Letter for CPI AEROSTRUCTURES INC (CVU) (CIK 0000889348) (CVU) — Sep 14, 2017
CPI AEROSTRUCTURES INC (CVU) (CIK 0000889348)
Date: Sept. 14, 2017 · CIK: 0000889348 · Accession: 0000000000-17-032644
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-220090
Letter
Mail Stop 3561 September 14, 2017 Douglas McCrosson President and Chief Executive Officer CPI Aerostructures, Inc. 91 Heartland Boulevard Edgewood, N Y 11717
Re: CPI Aerostructures, Inc. Registration Statement on Form S-3 Filed August 22, 2017 File No. 333-220090
Dear Mr. McCrosson :
We have limited our review of your registration statement to those issues we have addressed in our 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 this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply t o your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have ad ditional comments.
General
1. Please advise whether you believe you are eligible to conduct a primary offering pursuant to General Instruction I.B.1 of Form S -3. If so please provide us with your basis for that conclusion. If you do not meet that public float requirement and intend t o rely instead upon General Instruction I.B.6 of Form S -3, please revise to include the information required by Instruction 7 on the prospectus cover page.
We remind you that the company and its management are responsible for the accuracy and adequacy o f their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Douglas McCrosson CPI Aerostructures, Inc. September 14 , 201 7 Page 2
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effect ive date of the registration statement.
Please contact John Dana Brown at (202) 551 -3859 or me at (202) 551 -3217 with other questions.
Sincerely,
/s/ J. Nolan McWilliams
Show Raw Text
Mail Stop 3561
September 14, 2017
Douglas McCrosson
President and Chief Executive Officer
CPI Aerostructures, Inc.
91 Heartland Boulevard
Edgewood, N Y 11717
Re: CPI Aerostructures, Inc.
Registration Statement on Form S-3
Filed August 22, 2017
File No. 333-220090
Dear Mr. McCrosson :
We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply t o your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have ad ditional comments.
General
1. Please advise whether you believe you are eligible to conduct a primary offering pursuant
to General Instruction I.B.1 of Form S -3. If so please provide us with your basis for that
conclusion. If you do not meet that public float requirement and intend t o rely instead
upon General Instruction I.B.6 of Form S -3, please revise to include the information
required by Instruction 7 on the prospectus cover page.
We remind you that the company and its management are responsible for the accuracy
and adequacy o f their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Douglas McCrosson
CPI Aerostructures, Inc.
September 14 , 201 7
Page 2
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effect ive date of the registration
statement.
Please contact John Dana Brown at (202) 551 -3859 or me at (202) 551 -3217 with other
questions.
Sincerely,
/s/ J. Nolan McWilliams
J. Nolan McWilliams
Attorney -Advisor
Office of Transportation and Leisure
cc: Paul Lucido, Esq.
Graubard Miller