SEC Comment Letter 0000000000-22-012315 to PUBLIC CO MANAGEMENT CORP (PCMC) (CIK 0001141964) (PCMC)
PUBLIC CO MANAGEMENT CORP (PCMC) (CIK 0001141964)
Date: Nov. 14, 2022 · CIK: 0001141964 · Accession: 0000000000-22-012315
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File numbers found in text: 000-50098
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United States securities and exchange commission logo
November 14, 2022
Patrick McMahon
Chief Executive Officer
Public Company Management Corporation
9340 Wilshire Boulevard, Suite 203
Beverly Hills, CA 90212
Re:Public Company Management Corporation
Amendment No. 3 to Registration Statement on Form 10-12G
Filed October 25, 2022
File No. 000-50098
Dear Patrick McMahon:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response and any amendment you may file in response to
this comment, we may have additional comments. Unless we note otherwise, our references to
prior comments are to comments in our September 19, 2022 letter.
Amendment No. 3 to Form 10-12G filed October 25, 2022
Directors, Executive Officers, Promoters and Control Persons
Conflicts of Interest, page 20
1.We note your response to comment 1, including the disclosure on page 21 that Mr.
McMahon's primary business activities are as a consultant and independent contractor in
the legal cannabis industry. However, we also note your statement that the company's
management and the manager and members of Repository Services LLC "are now and
may in the future become shareholders, officers or directors of other companies which
may be engaged in business activities similar to those conducted by the Company."
Therefore, please revise to disclose the entities to which Mr. McMahon and Repository
Services LLC currently have fiduciary duties or contractual obligations.
FirstName LastNamePatrick McMahon
Comapany NamePublic Company Management Corporation
November 14, 2022 Page 2
FirstName LastName
Patrick McMahon
Public Company Management Corporation
November 14, 2022
Page 2
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 Peter McPhun at 202-551-3581 or Kristina Marrone at 202-551-3429 if
you have questions regarding comments on the financial statements and related matters. Please
contact Benjamin Holt at 202-551-6614 or Brigitte Lippmann at 202-551-3713 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Ron Stauber