SEC Comment Letter 0000000000-24-000125 to Texas Republic Capital Corp (CIK 0001560452)
Texas Republic Capital Corp (CIK 0001560452)
Date: Jan. 4, 2024 · CIK: 0001560452 · Accession: 0000000000-24-000125
AI Filing Summary & Sentiment
File numbers found in text: 000-55621
Letter
United States securities and exchange commission logo January 4, 2024 Shane S. Mitchell Chief Financial Officer, Secretary and Treasurer Texas Republic Capital Corporation 13215 Bee Cave Pkwy, Ste A120 Austin, TX 78738 Re:Texas Republic Capital Corporation Definitive Proxy Statement on Schedule 14A Filed March 31, 2023 File No. 000-55621 Dear Shane S. Mitchell: We have limited our review of your most recent definitive proxy statement to those issues we have addressed in our comments. Please respond to these comments by confirming that you will revise your future proxy disclosures in accordance with the topics discussed below. Definitive Proxy Statement on Schedule 14A filed March 31, 2023 Pay versus Performance, page 13 1.Please identify each non-PEO named executive officer included in the calculation of average non-PEO compensation and the fiscal years in which such persons are included. You may provide this information in a footnote to the pay versus performance table. See Regulation S-K Item 402(v)(3). 2.It appears that you have not provided the relationship disclosures you are required to provide pursuant to Regulation S-K Item 402(v)(5)(i) and (ii). Please provide this disclosure in its entirety. Although you may provide this information graphically, narratively, or a combination of the two, this disclosure must be separate from the pay versus performance table required by Regulation S-K Item 402(v)(1) and must provide a clear description of each separate relationship indicated in Regulation S-K Item 402(v)(5)(i) and(ii). Please note, it is not sufficient to state that no relationship exists, even if a particular measure is not used in setting compensation.
FirstName LastNameShane S. Mitchell Comapany NameTexas Republic Capital Corporation January 4, 2024 Page 2 FirstName LastName Shane S. Mitchell Texas Republic Capital Corporation January 4, 2024 Page 2 Please contact Alyssa Wall at 202-551-8106 or Amanda Ravitz at 202-551-3412 with any other questions. Sincerely, Division of Corporation Finance Disclosure Review Program
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United States securities and exchange commission logo
January 4, 2024
Shane S. Mitchell
Chief Financial Officer, Secretary and Treasurer
Texas Republic Capital Corporation
13215 Bee Cave Pkwy, Ste A120
Austin, TX 78738
Re:Texas Republic Capital Corporation
Definitive Proxy Statement on Schedule 14A
Filed March 31, 2023
File No. 000-55621
Dear Shane S. Mitchell:
We have limited our review of your most recent definitive proxy statement to those issues
we have addressed in our comments. Please respond to these comments by confirming that you
will revise your future proxy disclosures in accordance with the topics discussed below.
Definitive Proxy Statement on Schedule 14A filed March 31, 2023
Pay versus Performance, page 13
1.Please identify each non-PEO named executive officer included in the calculation of
average non-PEO compensation and the fiscal years in which such persons are
included. You may provide this information in a footnote to the pay versus performance
table. See Regulation S-K Item 402(v)(3).
2.It appears that you have not provided the relationship disclosures you are required to
provide pursuant to Regulation S-K Item 402(v)(5)(i) and (ii). Please provide this
disclosure in its entirety. Although you may provide this information graphically,
narratively, or a combination of the two, this disclosure must be separate from the pay
versus performance table required by Regulation S-K Item 402(v)(1) and must provide a
clear description of each separate relationship indicated in Regulation S-K Item
402(v)(5)(i) and(ii). Please note, it is not sufficient to state that no relationship exists, even
if a particular measure is not used in setting compensation.
FirstName LastNameShane S. Mitchell
Comapany NameTexas Republic Capital Corporation
January 4, 2024 Page 2
FirstName LastName
Shane S. Mitchell
Texas Republic Capital Corporation
January 4, 2024
Page 2
Please contact Alyssa Wall at 202-551-8106 or Amanda Ravitz at 202-551-3412 with any
other questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program