SEC Company Response from WILLOWTREE ADVISOR, INC. (CIK 0001298095) — Aug 2, 2005
WILLOWTREE ADVISOR, INC. (CIK 0001298095)
Date: Aug. 2, 2005 · CIK: 0001298095 · Accession: 0001002014-05-000526
AI Filing Summary & Sentiment
File numbers found in text: 333-117840
Letter
Securities and Exchange Commission Washington, D.C. 20549 RE: Willowtree Advisor, Inc. Form SB-2 Registration Statement File No. 333-117840
Dear Mr. Shuman:
In response to your verbal comment on July 19, 2005, please be advised as follows:
The Company is in compliance with the fair market value issues of Statement of Financial Accounting Standards 123 as currently composed and as revised. The stock was issued for the services to set up and research the Company's business purposes, which includes time prior to the initial incorporation. In accordance with SEC accounting guidance concerning the fair value of stock issued to an officer or promoter prior to a registration, when no other established means of valuation exists, the stock the officer received was valued at 3.5 cents per share, which represented a reasonable discount on the 5 cents per share registration value of the common stock. There are no current markets for the stock, nor any another holders other than this one officer.
Yours truly,
/s/ Conrad C. Lysiak
Conrad C. Lysiak
cc: Willowtree Advisor, Inc.
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CORRESP 1 filename1.htm Response to Comment Conrad C. Lysiak Attorney at Law 601 West First Avenue, Suite 503 Spokane, WA 99201 (509) 624-1475 Fax: (509) 747-1770 Email: cclysiak@qwest.net August 2, 2005 Mr. Mark P. Shuman Branch Chief - Legal Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 RE: Willowtree Advisor, Inc. Form SB-2 Registration Statement File No. 333-117840 Dear Mr. Shuman: In response to your verbal comment on July 19, 2005, please be advised as follows: The Company is in compliance with the fair market value issues of Statement of Financial Accounting Standards 123 as currently composed and as revised. The stock was issued for the services to set up and research the Company's business purposes, which includes time prior to the initial incorporation. In accordance with SEC accounting guidance concerning the fair value of stock issued to an officer or promoter prior to a registration, when no other established means of valuation exists, the stock the officer received was valued at 3.5 cents per share, which represented a reasonable discount on the 5 cents per share registration value of the common stock. There are no current markets for the stock, nor any another holders other than this one officer. Yours truly, /s/ Conrad C. Lysiak Conrad C. Lysiak cc: Willowtree Advisor, Inc.