CORRESP Filing
Avidbank Holdings, Inc.
Date: July 30, 2025 · CIK: 0001443575 · Accession: 0001829126-25-005584
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-288743
Letter
Re: Avidbank Holdings, Inc.
Craig D. Miller Manatt, Phelps & Phillips, LLP Direct Dial: (415) 291-7415 cmiller@manatt.com
July 30, 2025 Client-Matter: 42555-043
VIA EDGAR
U.S. Securities and Exchange Commission Division of Corporate Finance 100 F Street, NE
Washington, D.C. 20549
Registration Statement on Form S-1 Submitted July 18, 2025
CIK No. 0001443575
Ladies and Gentlemen:
On behalf of our client, Avidbank Holdings, Inc. (the " Company "), we hereby respectfully provide responses to comments of the staff (the " Staff ") of the Securities and Exchange Commission (the " Commission ") issued pursuant to our oral discussion with the Staff on July 29, 2025 (the " Comments ") relating to the Company's Registration Statement on Form S-1 (File No. 333-288743) as submitted with the Commission on July 18, 2025 (the " S-1 ").
In response to our discussions with the Staff and in connection with our proposed S-1/A submitted to the Commission via a Correspondence Letter from July 22, 2025, we intend to further revise our disclosures on the following pages of the draft Amendment No.1 to S-1 (the " S-1/A "), as attached hereto as Redline 1 , to (i) clarify risks associated with our Venture Lending business by including a separate risk factor on page 29, (ii) enhance the liquidity risk disclosure on page 92 and (iii) update the beneficial ownership information of the Company's 5% or more shareholders pursuant to Item 403 of the Regulation S-K on pages 147 - 148.
Should you have any questions regarding the foregoing responses or additional comments regarding our proposed edits to the S-1/A in connection with the Commission's Comments, please do not hesitate to contact Craig Miller at 415.291.7415 or Veronica Lah at 310.312.4130.
Sincerely
yours,
/s/
Craig D. Miller
Show Raw Text
CORRESP 1 filename1.htm Craig D. Miller Manatt, Phelps & Phillips, LLP Direct Dial: (415) 291-7415 cmiller@manatt.com July 30, 2025 Client-Matter: 42555-043 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporate Finance 100 F Street, NE Washington, D.C. 20549 Re: Avidbank Holdings, Inc. Registration Statement on Form S-1 Submitted July 18, 2025 CIK No. 0001443575 Ladies and Gentlemen: On behalf of our client, Avidbank Holdings, Inc. (the " Company "), we hereby respectfully provide responses to comments of the staff (the " Staff ") of the Securities and Exchange Commission (the " Commission ") issued pursuant to our oral discussion with the Staff on July 29, 2025 (the " Comments ") relating to the Company's Registration Statement on Form S-1 (File No. 333-288743) as submitted with the Commission on July 18, 2025 (the " S-1 "). In response to our discussions with the Staff and in connection with our proposed S-1/A submitted to the Commission via a Correspondence Letter from July 22, 2025, we intend to further revise our disclosures on the following pages of the draft Amendment No.1 to S-1 (the " S-1/A "), as attached hereto as Redline 1 , to (i) clarify risks associated with our Venture Lending business by including a separate risk factor on page 29, (ii) enhance the liquidity risk disclosure on page 92 and (iii) update the beneficial ownership information of the Company's 5% or more shareholders pursuant to Item 403 of the Regulation S-K on pages 147 - 148. Should you have any questions regarding the foregoing responses or additional comments regarding our proposed edits to the S-1/A in connection with the Commission's Comments, please do not hesitate to contact Craig Miller at 415.291.7415 or Veronica Lah at 310.312.4130. Sincerely yours, /s/ Craig D. Miller Craig D. Miller cc: Avidbank Holdings, Inc.