SEC Comment Letter for LGI Homes, Inc. (LGIH) (CIK 0001580670) (LGIH) — Oct 31, 2013
LGI Homes, Inc. (LGIH) (CIK 0001580670)
Date: Oct. 31, 2013 · CIK: 0001580670 · Accession: 0000000000-13-059816
AI Filing Summary & Sentiment
Reasoning
Letter
October 31, 2013 Via e -mail Eric Lipar Chief Executive Officer LGI Homes, Inc. 1450 Lake Robbins Drive, Suite 430 The Woodlands, Texas, 77380
Re: LGI Homes, Inc. Amendment No. 3 to Registration Statement on Form S-1 Submitted October 30 , 2013 File No. 333 -190853
Dear Mr. Lipar :
Please respond to this letter by providing the requested information and submitting an amended registration statement . 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 the information you provide in response to these comments and your amended regis tration statement, we may have additional comments.
Summary, page 1
1. Please disclose that information about your competitive position with respect to your private homebuilder peers is limited.
Exhibit 21.1
2. Please revise your list of subsidiaries to remove companies that are not currently your subsidiaries, such as the LGI -GTIS joint ventures.
Eric Lipar LGI Homes, Inc. October 31, 2013 Page 2
You may contact Tracey McKoy at (202)551 -3772 or Jeanne Baker at (202)551 -3691 if you have questions regarding comments on the financial statements and r elated matters. Please contact Leland Benton at (202)551 -3791 or Craig Slivka at (202)551 -3729 with any other questions.
Sincerely,
/s/ Craig E. Slivka, for
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October 31, 2013 Via e -mail Eric Lipar Chief Executive Officer LGI Homes, Inc. 1450 Lake Robbins Drive, Suite 430 The Woodlands, Texas, 77380 Re: LGI Homes, Inc. Amendment No. 3 to Registration Statement on Form S-1 Submitted October 30 , 2013 File No. 333 -190853 Dear Mr. Lipar : Please respond to this letter by providing the requested information and submitting an amended registration statement . 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 the information you provide in response to these comments and your amended regis tration statement, we may have additional comments. Summary, page 1 1. Please disclose that information about your competitive position with respect to your private homebuilder peers is limited. Exhibit 21.1 2. Please revise your list of subsidiaries to remove companies that are not currently your subsidiaries, such as the LGI -GTIS joint ventures. Eric Lipar LGI Homes, Inc. October 31, 2013 Page 2 You may contact Tracey McKoy at (202)551 -3772 or Jeanne Baker at (202)551 -3691 if you have questions regarding comments on the financial statements and r elated matters. Please contact Leland Benton at (202)551 -3791 or Craig Slivka at (202)551 -3729 with any other questions. Sincerely, /s/ Craig E. Slivka, for Pamela A. Long Assistant Director CC: Via E -mail Norman Miller, Esq. Winstead PC