SecProbe.io

April 3, 2020
Anthony Snow
President and Corporate Secretary
CBA Florida, Inc.
3753 Howard Hughes Parkway, Suite 200, Office #258
Las Vegas, NV 89169
Re:CBA Florida, Inc.
Preliminary Proxy Statement on Schedule 14A
Filed March 25, 2020
File No. 000-50746
Dear Mr. Snow:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Preliminary Proxy Statement on Schedule 14A
Proposal 2: Approval of Plan of Dissolution
Background of the Proposed Dissolution, page 27
1.Please revise the background section to discuss in greater detail the process for identifying
potential strategic transactions. Please describe all discussions, meetings, contacts and
reports among specific members of the board and/or management of the Company, and
representatives of potential counterparties as well as financial, economic and legal
advisors regarding the various options considered.
2.Please identify the independent economic consulting firm engaged by the Company to
make an assessment of potential unknown liabilities and provide the information required
by Item 1015(b) of Regulation M-A.

 FirstName LastNameAnthony Snow
 Comapany NameCBA Florida, Inc.
 April 3, 2020 Page 2
 FirstName LastName
Anthony Snow
CBA Florida, Inc.
April 3, 2020
Page 2
Amount and Timing of Estimated Liquidating Distributions to Shareholders, page 30
3.Please quantify the amounts that make up the Potential Additional Proceeds and the
amount of Transaction purchase price proceeds expected to be released from escrow in
May 2020. Please also identify and quantify the amounts that make up the $3.0 million to
$3.5 million intended for known, ongoing expenses and the $2.2 million for unknown,
contingent and/or conditional liabilities.
Interests of Certain Persons in the Dissolution, page 32
4.Please disclose the expected amount of compensation to be received by the Company’s
officers and directors above their regular compensation with respect to their services
related to the implementation of the plan of dissolution.
General
5.Please tell us how you considered the financial statement requirements in Item 14(b)(8)
through (b)(11) and 14(c)(1) of Schedule 14A.
            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.
            Please contact Chris Edwards at (202) 551-6761 or Celeste Murphy at (202) 551-3257
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Kenneth A. Schlesinger