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SEC Company Response from RESIDENTIAL FUNDING CORP (CIK 0001145701) — Sep 21, 2005

RESIDENTIAL FUNDING CORP (CIK 0001145701)
Date: Sept. 21, 2005 · CIK: 0001145701 · Accession: 0000950124-05-005485

AI Filing Summary & Sentiment

File numbers found in text: 333-126640

Date
September 21, 2005
Author
/s/ David A. Marple
Form
CORRESP
Company
RESIDENTIAL FUNDING CORP (CIK 0001145701)

Letter

Securities and Exchange Commission Washington, D.C. 20549 Residential Capital Corporation Registration Statement on Form S-4 (File No. 333-126640)

Re:

Dear Mr. Webb:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, Residential Capital Corporation hereby requests that the effectiveness of the referenced Registration Statement be accelerated so that said Registration Statement will become effective at 10:00 a.m. EDT on September 23, 2005, or as soon thereafter as practicable.

In connection with this acceleration request, the Company acknowledges that:

•

should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,
/s/ David A. Marple

Show Raw Text
CORRESP
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corresp

September 21, 2005

Mark S. Webb

Mail Stop 4561

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Residential Capital Corporation

Registration Statement on Form S-4 (File No. 333-126640)

Dear Mr. Webb:

     Pursuant to Rule 461 of the Securities Act of 1933, as amended, Residential Capital
Corporation hereby requests that the effectiveness of the referenced Registration Statement be
accelerated so that said Registration Statement will become effective at 10:00 a.m. EDT on
September 23, 2005, or as soon thereafter as practicable.

     In connection with this acceleration request, the Company acknowledges that:

    •

    should the Commission or the Staff, acting pursuant to delegated authority, declare
the filing effective, it does not foreclose the Commission from taking any action with
respect to the filing;

    •

    the action of the Commission or the Staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the Company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and

    •

    the Company may not assert this action as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

    Sincerely,

    /s/ David A. Marple

    David A. Marple

    General Counsel

Residential Capital Corporation

    cc:

    Philip J. Niehoff

RESIDENTIAL CAPITAL CORPORATION

8400 Normandale Lake Blvd., Suite 250

Minneapolis, MN 55437

t: 952.857.7000

w: www.rescapholdings.com