SecProbe.io

November 16, 2012

Via E -mail
Sergio Galli, President
Band Rep Management, Inc.
112 North Curry Street
Carson City, NV 89703

Re: Band Rep Management, Inc.
Amendment No. 2 to Registration Statement on Form S -1
Filed October 29, 2012
  File No. 333-183373

Dear Mr. Sergio :

We have reviewed Amendment No. 2 to your registration statement  and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.

Please resp ond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response .

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

General

1. We note your response to comment 1 of our letter dated October 19, 2012.  We reissue
our comment.  Please affirmatively confirm to us that you have not authorized anyone  to
provide any written materials to qualified institutional buyers or institutional accredited
investors  on your behalf.

2. Please update the financial information within your filing.   At this time, you may do so
on an unaudited basis.   Reference is made to Rule 8 -08 of Regulation S -X.

Sergio Galli, President
Band Rep Management, Inc.
November 16, 2012
Page 2

 Risk Factors, page 11

The Company may not be able to  generate sufficient cash flow …, page 12

3. We note your response to comment 4 of our letter dated October 19, 2012.  We note that
your current liabilities are $1,345.  Please disclose to whom this amount is owed and the
interest rate applicable to this deb t.   Please advise whether there is a written agreement
associated with your debt obligation.  Please make similar revisions to your disclosure on
page 40.

Description of Business, page 24

Regulatory Matters, page 26

4. We note your response to comment 8 of our letter dated October 19, 2012. We reissue
our comment.  Please expand your disclosure to discuss the regulations applicable to
companies based in Canada or other jurisdictions in which you intend to conduct
business, not just securities regulations or Nevada law.  Please discuss the impact these
regulations may have on investors. If there are no laws that would impact investors,
please affirmatively state this.

Exhibits

5. Please revise the exhibit list to indicate the filing where each exhibit may be  located.
Additionally, please revise to indicate that counsel’s consent is located within the legal
opinion.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disc losures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement please provide  a written statement from the company
acknowledging 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;

 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 disclosure in the filing; and

Sergio Galli, President
Band Rep Management, Inc.
November 16, 2012
Page 3

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date  of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offe ring of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact Howard Efron  at (202)551 -3439 or Kevin Woody, Accounting Branch
Chief  at (202)551 -3629 if you have questions regarding comments on the financial statements
and related matters.  Please contact  Stacie Gorman  at (202)551 -3585 or me at (202)551 -3233
with any other questions.

Sincerely,

/s/ Tom Kluck

 Tom Kluck
Legal Branch Chief