SEC Comment Letter for Cohen & Co Inc. (COHN) (CIK 0001270436) (COHN) — Jan 8, 2014
Cohen & Co Inc. (COHN) (CIK 0001270436)
Date: Jan. 8, 2014 · CIK: 0001270436 · Accession: 0000000000-14-000861
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January 7, 2014 Via E -mail Joseph W. Pooler, Jr. Executive Vice President, Chief Financial Officer and Treasurer Institutional Financial Markets, Inc. 2929 Arch Street Philadelphia, PA 19104 Re: Institutional Financial Markets, Inc. Amendment No. 1 to Registration Statement on Form S-3 Filed December 11 , 2013 File No . 333 -191887 Dear Mr. Pooler : We have reviewed your ame ndment and your response dated December 11, 2013 a nd have the following comment. Please respond to this letter by amending your registration statement and provid ing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, pleas e tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to t his comme nt, we may have additional comments. Exhibit 5.1 1. Please have counsel revise to opine that the Rights are and will be binding obligation s of the Company. Please contact Michael Seaman at (202) 551 -3366 with any questions. Sincerely, /s/ Michael Seaman for Suzanne Hayes Assistant Director