SEC Comment Letter for HomeStreet, Inc. (HMST) (CIK 0001518715) (MCHB) — May 1, 2018
HomeStreet, Inc. (HMST) (CIK 0001518715)
Date: May 1, 2018 · CIK: 0001518715 · Accession: 0000000000-18-013381
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
April 30, 2018
Peter D. Fetzer, Esq.
Foley & Lardner LLP
777 East Wisconsin Avenue
Milwaukee, WI 53202 -5306
Re: HomeStreet, Inc.
Additional Definitive Soliciting Material s filed by Blue Lion Opportunity
Master Fund, L.P. et al.
Filed April 26, 2018
File No. 1 -35424
Dear Mr. Fetzer :
We have reviewed the above -captioned filing s and have the following comments.
In some of our comments, we may ask you to provide us with information so that we may
better understand your disclosure.
Please respond to this letter by amending the filing s or by advising us when you
will provide the requested response . If you do not believe our comment s apply to your
facts and circumstances or do not believe an amendment is appropriate, pleas e tell us why
in your response.
After reviewing your response and any amendment you may file in response to
these comments, we may have additional comments .
1. Please provide us with the legal basis for your implicit conclusion that HomeStreet
was required to disclose the business relationship between Mr. Mason and the father
of Mr. Smith and the related loan that y ou describe in both filings. To the extent you
have no clear basis, please revise the filings accordingly.
2. Two of the three charts presented in your letter to shareholders include an asterisk by
the title of the respective chart but no explanation as to t he source of the information
contained in the chart. Please revise.
* * *
Peter D. Fetzer, Esq .
April 30, 2018
Page 2
2 Please contact David Plattner, Special Counsel, at (202) 551 -8094, or me, at (202)
551-3619, if you have any questions regarding our comment s.
Sincerely,
/s/ Daniel F. Duchovny
Daniel F. Duchovny
Special Counsel
Office of Mergers and Acquisitions