SEC Company Response from ECC Capital (ECRO) — Jan 18, 2005
ECC Capital CORP
Date: Jan. 18, 2005 · CIK: 0001300317 · Accession: 0001193125-05-007797
AI Filing Summary & Sentiment
File numbers found in text: 333-118253
Referenced dates: January 5, 2005
Letter
Division of Corporation Finance United States Securities and Exchange Commission Re: ECC Capital Corporation Registration Statement on Form S-11 filed on August 13, 2004, as amended by Amendment No. 1 to Form S-11 filed on October 29, 2004 and Amendment No. 2 to Form S-11 (File No. 333-118253) filed on December 17, 2004.
Dear Mr. Telewicz:
Thank you for taking the time today to discuss certain comments to ECC Capital Corporation’s (the “Company”) Amendment No. 2 contained in the comment letter dated January 5, 2005. As we discussed, we have included below the supplemental information you requested in support of the Company’s draft response to comment number 13.
Financial Statements
Note N – Stock Options, page F-27
13. We have reviewed your response to our prior comment 49 and the related changes to your disclosures. It appears that the value of your stock has almost doubled from August 2004 to September 2004. In a supplemental response, explain the changes in circumstances that have caused the increase in the value of your stock.
Supplemental Information:
*
* Confidential Treatment Requested by ECC Capital Corporation
Mr. Robert Telewicz
January 18, 2005
Page
LATHAM & WATKINS LLP
Warm regards,
/s/ Jeevan B. Gore
Jeevan B. Gore
of LATHAM & WATKINS LLP
cc: Roque Santi
Greg Lubushkin
William J. Cernius
Show Raw Text
CORRESP 1 filename1.htm SEC Correspondence [LETTERHEAD OF LATHAM & WATKINS LLP] January 18, 2005 Mr. Robert Telewicz Staff Accountant Division of Corporation Finance United States Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549-0306 Re: ECC Capital Corporation Registration Statement on Form S-11 filed on August 13, 2004, as amended by Amendment No. 1 to Form S-11 filed on October 29, 2004 and Amendment No. 2 to Form S-11 (File No. 333-118253) filed on December 17, 2004. Dear Mr. Telewicz: Thank you for taking the time today to discuss certain comments to ECC Capital Corporation’s (the “Company”) Amendment No. 2 contained in the comment letter dated January 5, 2005. As we discussed, we have included below the supplemental information you requested in support of the Company’s draft response to comment number 13. Financial Statements Note N – Stock Options, page F-27 13. We have reviewed your response to our prior comment 49 and the related changes to your disclosures. It appears that the value of your stock has almost doubled from August 2004 to September 2004. In a supplemental response, explain the changes in circumstances that have caused the increase in the value of your stock. Supplemental Information: * * Confidential Treatment Requested by ECC Capital Corporation Mr. Robert Telewicz January 18, 2005 Page 2 LATHAM & WATKINS LLP Warm regards, /s/ Jeevan B. Gore Jeevan B. Gore of LATHAM & WATKINS LLP cc: Roque Santi Greg Lubushkin William J. Cernius