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SEC Comment Letter for CASTLE ARCH REAL ESTATE INVESTMENT COMPANY, LLC (CIK 0001321742) — Jun 15, 2005

CASTLE ARCH REAL ESTATE INVESTMENT COMPANY, LLC (CIK 0001321742)
Date: June 15, 2005 · CIK: 0001321742 · Accession: 0000000000-05-030055

AI Filing Summary & Sentiment

Date
May 27, 2005
Author
Karen Garnett
Form
UPLOAD
Company
CASTLE ARCH REAL ESTATE INVESTMENT COMPANY, LLC (CIK 0001321742)

Letter

May 27, 2005 Mail Stop 4561 Kirby D. Cochran Chairman and Chief Executive Officer Castle Arch Real Estate Investment Company, LLC 9595 Wilshire, Penthouse 1000 Beverly Hills, CA 90212

Re: Castle Arch Real Estate Investment Company, LLC Form 10/A-1 File No. 0-51230 Filed May 17, 2005

Dear Mr. Cochran:

This is to advise you that a preliminary review of the above registration statement indicates that it fails in numerous material respects to comply with the requirements of the Securities Exchange Act of 1934, the rules and regulations under that Act, and the requirements of the form. For example, it appears your filing should include updated interim financial statements for the most recent quarterly period pursuant to Rule 3-12 of Regulation S-X. For this reason, we will not perform a detailed examination of the registration statement and we will not issue comments because to do so would delay the review of other disclosure documents that do not appear to contain comparable deficiencies.

You are advised that the registration statement will become effective through operation of law on May 31, 2005, and, if it becomes effective in its present form, we would be required to consider what recommendation, if any, we should make to the Commission.

We suggest that you consider submitting a substantive amendment correcting the deficiencies or a request for withdrawal of the registration statement before it becomes effective. Sincerely,

Karen Garnett Assistant Director

cc: David Hunt, Esq. (via facsimile)

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

							May 27, 2005

      Mail Stop 4561

Kirby D. Cochran
Chairman and Chief Executive Officer
Castle Arch Real Estate Investment Company, LLC
9595 Wilshire, Penthouse 1000
Beverly Hills, CA 90212

Re:	Castle Arch Real Estate Investment Company, LLC
	Form 10/A-1
	File No. 0-51230
      Filed May 17, 2005

Dear Mr. Cochran:

	This is to advise you that a preliminary review of the above
registration statement indicates that it fails in numerous
material
respects to comply with the requirements of the Securities
Exchange
Act of 1934, the rules and regulations under that Act, and the
requirements of the form.  For example, it appears your filing
should
include updated interim financial statements for the most recent
quarterly period pursuant to Rule 3-12 of Regulation S-X.  For
this
reason, we will not perform a detailed examination of the
registration statement and we will not issue comments because to
do
so would delay the review of other disclosure documents that do
not
appear to contain comparable deficiencies.

	You are advised that the registration statement will become
effective through operation of law on May 31, 2005, and, if it
becomes effective in its present form, we would be required to
consider what recommendation, if any, we should make to the
Commission.

	We suggest that you consider submitting a substantive
amendment
correcting the deficiencies or a request for withdrawal of the
registration statement before it becomes effective.
							Sincerely,

							Karen Garnett
							Assistant Director

cc:	David Hunt, Esq. (via facsimile)

</TEXT>
</DOCUMENT>