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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

Date
December 13, 2004
Author
BB&T Capital Markets, a division of Scott &
Form
CORRESP
Company
Comstock Holding Companies, Inc. (CHCI) (CIK 0001299969)

Letter

United States Securities and Exchange Commission Division of Corporation Finance 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 &

Show Raw Text
CORRESP
1
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
2