SEC Comment Letter for ABC Funding, Inc (CIK 0001296595) — Mar 30, 2005
ABC Funding, Inc (CIK 0001296595)
Date: March 30, 2005 · CIK: 0001296595 · Accession: 0000000000-05-014891
AI Filing Summary & Sentiment
File numbers found in text: 333-121070
Letter
February 24, 2005 Mail Stop 4-6 Harold Barson ABC Funding, Inc. 9160 South 300 West Sandy, UT 84070
Re: ABC Funding, Inc. Amendment 1 to Form SB-2 filed February 4, 2005 Registration no. 333-121070
Dear Mr. Barson:
We have reviewed your amendment and have the following comments.
Management`s Discussion and Analysis Liquidity, page 15-16
We note that the changes in disclosure made in response to our comments regarding ABC/s liquidity seem to be answered in the section headed "Operations". It appears that the comments and responses more appropriately address issues of liquidity and should be discussed under that caption.
As previously requested, clarify the types of obligations to which you are referring in the disclosure in this section. Further, as previously requested, in the Business section, discuss how the use of independent contractors fits within your business strategy.
As previously requested, include disclosure regarding Mr. Barson`s or Mr. Brown`s previous experience that suits them to manage the financial reporting requirements of ABC.
Financial Statements General
Revise your filing to include updated financial statements consistent with the requirements of Item 310(g) of Regulation S-B.
Revise your filing to include an updated consent from your independent accountant. See Item 601 of Regulation S-B. General
You may contact Sherri Bowen at (301) 262-9132 or Brad Skinner, Branch Chief - Accounting at (202) 942-1922 if you have questions regarding comments on the financial statements and related matters. Please contact Hugh Fuller at (202) 942-1813 or me at (202) 942- with any other questions.
Sincerely,
Barbara C. Jacobs
Assistant Director
Show Raw Text
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
February 24, 2005
Mail Stop 4-6
Harold Barson
ABC Funding, Inc.
9160 South 300 West
Sandy, UT 84070
Re: ABC Funding, Inc.
Amendment 1 to Form SB-2 filed February 4, 2005
Registration no. 333-121070
Dear Mr. Barson:
We have reviewed your amendment and have the following
comments.
Management`s Discussion and Analysis
Liquidity, page 15-16
We note that the changes in disclosure made in response to our
comments regarding ABC/s liquidity seem to be answered in the
section
headed "Operations". It appears that the comments and responses
more
appropriately address issues of liquidity and should be discussed
under that caption.
As previously requested, clarify the types of obligations to which
you are referring in the disclosure in this section. Further, as
previously requested, in the Business section, discuss how the use
of
independent contractors fits within your business strategy.
As previously requested, include disclosure regarding Mr. Barson`s
or
Mr. Brown`s previous experience that suits them to manage the
financial reporting requirements of ABC.
Financial Statements
General
Revise your filing to include updated financial statements
consistent
with the requirements of Item 310(g) of Regulation S-B.
Revise your filing to include an updated consent from your
independent accountant. See Item 601 of Regulation S-B.
General
You may contact Sherri Bowen at (301) 262-9132 or Brad
Skinner,
Branch Chief - Accounting at (202) 942-1922 if you have questions
regarding comments on the financial statements and related
matters.
Please contact Hugh Fuller at (202) 942-1813 or me at (202) 942-
1800
with any other questions.
Sincerely,
Barbara C. Jacobs
Assistant Director
CC: Gary B. Wolff
805 Third Avenue, 21st Floor
New York, NY 10022
FAX Number (212) 644-6498
</TEXT>
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