SEC Company Response from Refco Finance Inc. (CIK 0001305464) — Apr 6, 2005
Refco Finance Inc. (CIK 0001305464)
Date: April 6, 2005 · CIK: 0001305464 · Accession: 0001047469-05-009419
AI Filing Summary & Sentiment
File numbers found in text: 333-119701
Letter
VIA EDGAR AND FACSIMILE Division of Corporation Finance Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re:Refco Group Ltd., LLC/Refco Finance Inc. Registration Statement on Form S-4 (No. 333-119701)
Dear Mr. Windsor:
Refco Group Ltd., LLC and Refco Finance Inc. (collectively, the "Company"), hereby respectfully requests that the effective date of the Company's Registration Statement on Form S-4 (File No. 333-119701) (the "Registration Statement") be accelerated so that it becomes effective at 4:00 p.m. (Eastern time) on April 8, 2005 or as soon thereafter as practicable.
In connection with the filing of the Registration Statement, the Company acknowledges that the disclosure in the filing is the responsibility of the Company. The Company further acknowledges that staff comment or changes in response to staff comment in the disclosure in the Registration Statement may not be asserted in any defense in any proceeding which may be brought by any person. The Company represents to the Commission that should the Commission or the staff acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing and the Company represents that it will not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
The Company further acknowledges that the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosures in the filing.
I hereby confirm to you that the Company is aware of its obligations under the Act and the Securities Exchange Act of 1934, as amended, with respect to the public offering of securities specified in the Registration Statement.
Please call the undersigned at (212) 693-7200 to confirm such effectiveness and if you have any questions.
Very truly yours,
/s/ PHILLIP R. BENNETT Phillip R. Bennett
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REFCO GROUP LTD., LLC
REFCO FINANCE INC.
One World Financial Center
200 Liberty Street, Tower A
New York, New York 10281
April 6,
2005
VIA
EDGAR AND FACSIMILE
Mr. Christian
N. Windsor
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re:Refco
Group Ltd., LLC/Refco Finance Inc.
Registration Statement on Form S-4 (No. 333-119701)
Dear
Mr. Windsor:
Refco
Group Ltd., LLC and Refco Finance Inc. (collectively, the "Company"), hereby respectfully requests that the effective date of the Company's Registration Statement on
Form S-4 (File No. 333-119701) (the "Registration Statement") be accelerated so that it becomes effective at 4:00 p.m. (Eastern time) on April 8,
2005 or as soon thereafter as practicable.
In
connection with the filing of the Registration Statement, the Company acknowledges that the disclosure in the filing is the responsibility of the Company. The Company further
acknowledges that
staff comment or changes in response to staff comment in the disclosure in the Registration Statement may not be asserted in any defense in any proceeding which may be brought by any person. The
Company represents to the Commission that should the Commission or the staff acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing and the Company represents that it will not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities
laws of the United States.
The
Company further acknowledges that the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective does not relieve the Company
from its full responsibility for the adequacy and accuracy of the disclosures in the filing.
I
hereby confirm to you that the Company is aware of its obligations under the Act and the Securities Exchange Act of 1934, as amended, with respect to the public offering of securities
specified in the Registration Statement.
Please
call the undersigned at (212) 693-7200 to confirm such effectiveness and if you have any questions.
Very truly yours,
/s/ PHILLIP R. BENNETT Phillip R. Bennett
cc:Alexander
D. Lynch, Esq.
Weil, Gotshal & Manges LLP
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REFCO GROUP LTD., LLC REFCO FINANCE INC. One World Financial Center 200 Liberty Street, Tower A New York, New York 10281