SEC Company Response from Comstock Holding Companies, Inc. (CHCI) (CIK 0001299969) (CHCI) — Dec 9, 2004
Comstock Holding Companies, Inc. (CHCI) (CIK 0001299969)
Date: Dec. 9, 2004 · CIK: 0001299969 · Accession: 0001047469-04-036695
AI Filing Summary & Sentiment
File numbers found in text: 333-118193
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CORRESP
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filename1.htm
BB&T Capital Markets
Corporate Finance
909 East Main Street (23218)
P.O. Box 1575
Richmond, VA 23218-1575
December 9,
2004
United
States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W. Mail Stop 4-4
Washington, D.C. 20549-0404
Attn: Matt Franker
Re:Comstock
Homebuilding Companies, Inc.
Form S-1
Registration Statement No. 333-118193
Dear
Mr. Franker:
Pursuant
to Rule 461, promulgated under the Securities Act of 1933, as amended (the "Securities Act"), on behalf of the Underwriters, we hereby join in the request of Comstock
Homebuilding Companies, Inc. that the effective date of the Registration Statement on Form S-1 (No. 333-118193) be accelerated so that such Registration Statement will become
effective on December 13, 2004 at 4:00 p.m. Eastern Daylight Time or as soon thereafter as practical.
In
accordance with Rule 460 and Rule 418(a)(7) of the General Rules and Regulations under the Securities Act, we advise you that the preliminary prospectus dated
November 24, 2004 was distributed commencing November 29, 2004 and through the date of this letter as follows:
2246 to 2
Underwriters
55 to 2
Dealers
604 to 604
Institutions
4480 to 44
Other
7385 to 652
Total
We
have taken reasonable steps to make the information contained in the Registration Statement conveniently available to underwriters and dealers who will participate in the distribution
of the securities registered thereunder.
This
will also confirm that the undersigned has complied with Rule 15c2-8 of the General Rules and Regulations of the Securities Exchange Act of 1934, as amended, with respect to
the preliminary prospectus dated November 24, 2004 and will comply with such Rule with respect to the final prospectus. We have been advised that participating underwriters have complied and
will comply with Rule 15c2-8.
Please
call Randy Parks (804) 788-7375 or Gerry McCartin (703) 714-7513 of Hunton & Williams LLP or me (804) 787-8268 with any questions or comments.
Sincerely,
BB&T Capital Markets, a division of Scott &
Stringfellow, Inc.
Robert W. Baird & Co.
Ferris, Baker Watts, Incorporated
By: BB&T Capital Markets
/s/ DAVID HOLMES
David Holmes
Managing Director
cc:Christopher
Clemente, Comstock Homebuilding Companies, Inc.
Randall Parks, Hunton & Williams LLP
Gerald McCartin, Hunton & Williams LLP
Patrick Martin, BB&T Capital Markets
Mark Decker, Sr., Robert W. Baird & Co.
Richard K. Prins, Ferris, Baker Watts, Incorporated
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