SEC Company Response from BOSTON CAPITAL TAX CREDIT FUND IV LP (CIK 0000913778) — Feb 6, 2020
BOSTON CAPITAL TAX CREDIT FUND IV LP (CIK 0000913778)
Date: Feb. 6, 2020 · CIK: 0000913778 · Accession: 0000913778-20-000001
AI Filing Summary & Sentiment
File numbers found in text: 000-26200
Letter
VIA EDGAR Division of Corporation Finance Office of Real Estate & Construction United States Securities and Exchange Commission Re: Boston Capital Tax Credit Fund IV L.P. Form 10-K for the year ended 3/31/2019 Filed on 6/20/2019 File No. 000-26200
Dear Mr. Demarest and Mr. Esquivel:
This letter is submitted by Boston Capital Tax Credit Fund IV L.P. (the "Partnership" or the "Fund") in response to the comments of the staff (the "Staff") of the Division of Corporation Finance of the Securities and Exchange Commission (the "Commission") with respect to the Partnership's Form 10-K for the year ended March 31, 2019 (File No. 000-26200) (the "Form 10-K"). For your convenience, the Staff's comments are reproduced below before the Partnership's answers.
FORM 10-K FOR THE YEAR ENDED MARCH 31, 2019
Item 9a. Controls and Procedures, page 95
In future filings, revise your disclosure to include a statement that the certifications of the Principal Executive Officer and Principal Financial Officer, filed as exhibits, are applicable to each of the 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.
Response: The disclosure in our future filings will 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 as a whole. Additionally, we confirm that management's conclusion on the effectiveness of the Partnership's internal control over financial reporting as of March 31, 2019, as disclosed in the Form 10-K, is applicable to each series individually, as well as to the Fund as a whole. In the Partnership's future filings, we will clarify that the scope of management's assessment of internal control over financial reporting and conclusions thereof, covers each series individually, as well as the Fund as a whole.
Exhibit 13
Report of Independent Registered Public Accounting Firm, page F-3
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 series. Refer to Question 104.01 of the Securities Act Sections Compliance and Disclosure Interpretations.
Response: We have consulted with our independent auditor, and our independent auditor confirmed, that the financial statements for each series individually were covered in their audit opinion dated June 20, 2019. Our independent auditor also confirmed that their report included in future Form 10-K filings by the Partnership, if any, will include appropriate references to the covered series.
Please contact me at (617) 624-8820 with any further comments or questions you may have.
Sincerely,
By: /S/ Marc N. Teal
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CORRESP 1 filename1.htm Boston Capital Boston Capital February 6, 2020 VIA EDGAR William Demarest, Staff Accountant Isaac Esquivel, Staff Accountant Division of Corporation Finance Office of Real Estate & Construction United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Boston Capital Tax Credit Fund IV L.P. Form 10-K for the year ended 3/31/2019 Filed on 6/20/2019 File No. 000-26200 Dear Mr. Demarest and Mr. Esquivel: This letter is submitted by Boston Capital Tax Credit Fund IV L.P. (the "Partnership" or the "Fund") in response to the comments of the staff (the "Staff") of the Division of Corporation Finance of the Securities and Exchange Commission (the "Commission") with respect to the Partnership's Form 10-K for the year ended March 31, 2019 (File No. 000-26200) (the "Form 10-K"). For your convenience, the Staff's comments are reproduced below before the Partnership's answers. FORM 10-K FOR THE YEAR ENDED MARCH 31, 2019 Item 9a. Controls and Procedures, page 95 In future filings, revise your disclosure to include a statement that the certifications of the Principal Executive Officer and Principal Financial Officer, filed as exhibits, are applicable to each of the 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. Response: The disclosure in our future filings will 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 as a whole. Additionally, we confirm that management's conclusion on the effectiveness of the Partnership's internal control over financial reporting as of March 31, 2019, as disclosed in the Form 10-K, is applicable to each series individually, as well as to the Fund as a whole. In the Partnership's future filings, we will clarify that the scope of management's assessment of internal control over financial reporting and conclusions thereof, covers each series individually, as well as the Fund as a whole. Exhibit 13 Report of Independent Registered Public Accounting Firm, page F-3 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 series. Refer to Question 104.01 of the Securities Act Sections Compliance and Disclosure Interpretations. Response: We have consulted with our independent auditor, and our independent auditor confirmed, that the financial statements for each series individually were covered in their audit opinion dated June 20, 2019. Our independent auditor also confirmed that their report included in future Form 10-K filings by the Partnership, if any, will include appropriate references to the covered series. Please contact me at (617) 624-8820 with any further comments or questions you may have. Sincerely, By: /S/ Marc N. Teal Marc N. Teal Principal Financial Officer cc: Marc Teal