CORRESP Filing
REDWOOD TRUST INC
Date: Aug. 6, 2025 · CIK: 0000930236 · Accession: 0001104659-25-074760
AI Filing Summary & Sentiment
File numbers found in text: 001-13759
Referenced dates: July 24, 2025
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CORRESP
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One Belvedere Place
Suite 300
Mill Valley, CA 94941
Phone 415.389.7373
VIA EDGAR
August 6, 2025
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.W.
Washington, D.C. 20549
Attn:
William Demarest
Isaac Esquivel
Office of Real Estate & Construction
Re:
Redwood Trust, Inc.
Response to Comments on:
Form 10-K for the Year Ended December 31, 2024
File No. 001-13759
Dear Messrs. Demarest and Esquivel,
On behalf of Redwood Trust, Inc. ("Redwood"
or the "Company"), I hereby provide the following responses in reply to the Staff's comment letter dated July 24,
2025 (the "Comment Letter") in connection with the above-referenced Annual Report on Form 10-K (the "Form 10-K").
For your convenience, our responses are preceded with an italicized recitation of the comments set forth in the Comment Letter.
Form 10-K for the Year Ended December 31, 2024
Item 1A. Risk Factors
Through certain of our wholly-owned subsidiaries
we have engaged in the past…, page 35
1.
We note your disclosure on page 37
that you have incorporated blockchain technology into securitization transactions. Please clarify which blockchain you use and how the
blockchain is used in the securitization process. Describe how you access the blockchain and the functions you have under this access.
Redwood respectfully advises the Staff that
Redwood engages LiquidFi, Inc. ("LiquidFi"), a corporation in which Redwood owns a minority interest, to act as
distributed ledger agent for certain residential mortgage-backed securitization transactions sponsored by subsidiaries of Redwood. In this role, LiquidFi leverages its blockchain-based technology to provide end users with reporting of loan level payments
of principal and interest on the underlying residential mortgages by maintaining a platform at https://www.liquidfi.io/deals/. End users can access this platform to view updated information on each business day relating to payments received on the servicing released
mortgage loans, which are mirrored through digital entries on the Stellar blockchain.
LiquidFi, in its capacity as distributed ledger
agent, is responsible for maintaining its digital asset platform and performing the duties it is obligated to perform under the distributed
ledger agent agreement. Additionally, one or more third-party residential mortgage sub-servicers for these securitization transactions
is responsible for creating the daily payment files that the distributed ledger agent relies upon to perform its duties under the distributed
ledger agent agreement, including making payment information available to end users on the distributed ledger agent's platform.
The distributed ledger agent receives, processes, uploads and distributes information to and from its digital asset platform, and/or grants
end users access to the same. The distributed ledger agent relies on information technology networks and systems, including the internet,
to receive, process, distribute and otherwise make information available to end users in connection with its obligations under the distributed
ledger agent agreement.
August 6, 2025
Page 2 of 2
2.
Related to the comment above, tell us
whether any "tokenized" digital securities have been issued to date and your accounting policies related to any such issuances.
Redwood respectfully advises the Staff that Redwood has not issued any such "tokenized"
digital securities to date, and has no imminent plans to do so, therefore, Redwood has not adopted any accounting policies related to
such issuances.
* * *
Should you have any further comments or questions
about this letter, please contact me by telephone at 415-384-3827 or by email at brooke.carillo@redwoodtrust.com .
Very truly yours,
Redwood Trust, Inc.
By:
/s/
Brooke Carillo
Brooke Carillo
Chief Financial Officer