SEC Comment Letter for Tecnoglass Inc. (TGLS) (CIK 0001534675) (TGLS) — Jul 25, 2016

Tecnoglass Inc. (TGLS) (CIK 0001534675)
Date: July 25, 2016 · CIK: 0001534675 · Accession: 0000000000-16-085638

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AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

June 28, 2016

Author

/s/ Jay Ingram

Form

UPLOAD

Company

Tecnoglass Inc. (TGLS) (CIK 0001534675)

Letter

Mail Stop 4631 July 25 , 2016 Via E -mail Jose Dias Chief Executive Officer Tecnoglass Inc. Avenida Circunvalar a 100 mts de la Via 40 Barrio Las Flores Barranquilla, Colombia

Re: Tecnoglass Inc. Post-Effective Amendment No. 5 to Form S -1 on Form S -1 Filed June 28, 2016 File No. 333 -193882

Dear Mr. Dias:

We have reviewed your post -effective amendment and have the following comment.

Note 7. Debt, page FS -52

1. We note your disclosure in your form 10 -Q for the period ended March 31, 2016 that certain obligations include covenants and events of default including requirements that the Company maintain a minimum debt to EBITDA ratio, a minimum debt service ratio, total debt to total assets ratio and sales growth ratios. Please revise your filing to disclose whether you were in compliance with such covenants at the end of the periods presented.

Please contact David Korvin, Staff Attorney at 202 -551-3236 or me at 202-551-3397 with any questions.

Sincerely,
/s/ Jay Ingram

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Mail Stop 4631       July 25 , 2016

Via E -mail
Jose Dias
Chief Executive  Officer
Tecnoglass Inc.
Avenida Circunvalar a 100 mts de la Via 40
Barrio Las Flores
Barranquilla, Colombia

 Re: Tecnoglass  Inc.
  Post-Effective Amendment No. 5 to Form S -1 on Form S -1
  Filed June 28, 2016
  File No. 333 -193882

Dear Mr. Dias:

 We have reviewed your post -effective amendment and have the following comment.

Note 7. Debt, page FS -52

1. We note your disclosure in your form 10 -Q for the period ended March 31, 2016 that
certain obligations include covenants and events of default including requirements that
the Company maintain a minimum debt to EBITDA ratio, a minimum debt service ratio,
total debt to total assets ratio and sales growth ratios.  Please revise your filing to disclose
whether you were in compliance with such covenants at the end of the periods presented.

Please contact David Korvin, Staff Attorney at 202 -551-3236 or me at 202-551-3397
with any questions.

Sincerely,

        /s/ Jay Ingram

        Jay Ingram
Legal Branch Chief
Office of Manufacturing and
Construction

cc: Via E -mail
Jeffrey Gallant , Esq.
 Graubard Miller

SecProbe.io