SEC Comment Letter 0000000000-23-010773 to GROUNDFLOOR FINANCE INC. (CIK 0001588504)
GROUNDFLOOR FINANCE INC. (CIK 0001588504)
Date: Sept. 29, 2023 · CIK: 0001588504 · Accession: 0000000000-23-010773
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File numbers found in text: 024-12013
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United States securities and exchange commission logo
September 29, 2023
Nick Bhargava
Chief Financial Officer
Groundfloor Finance Inc.
600 Peachtree Street, Suite 810
Atlanta, GA 30308
Re:Groundfloor Finance Inc.
Offering Statement on Form 1-A
Post-qualification Amendment No. 3
Filed September 22, 2023
File No. 024-12013
Dear Nick Bhargava:
We have reviewed your amendment and have the following comment. In our comment,
we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe our comment applies 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 offering statement and the information you
provide in response to this comment, we may have additional comments.
Form 1-A POS filed September 22, 2023
General
1.Please tell us what consideration you gave to updating your post-qualification amendment
on Form 1-A to include interim financial statements and other relevant information from
your Form 1-SA for the semiannual period ended June 30, 2023, which you filed on
August 29, 2023. Refer to Rule 252(a) of Regulation A and General Instruction III(c) of
Form 1-A.
We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
We remind you that the company and its management are responsible for the accuracy
FirstName LastNameNick Bhargava
Comapany NameGroundfloor Finance Inc.
September 29, 2023 Page 2
FirstName LastName
Nick Bhargava
Groundfloor Finance Inc.
September 29, 2023
Page 2
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contact Pearlyne Paulemon at 202-551-8714 or Dorrie Yale at 202-551-8776 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Brian Korn