SEC Comment Letter 0000000000-24-006441 to GROUNDFLOOR FINANCE INC. (CIK 0001588504)
GROUNDFLOOR FINANCE INC. (CIK 0001588504)
Date: June 5, 2024 · CIK: 0001588504 · Accession: 0000000000-24-006441
AI Filing Summary & Sentiment
File numbers found in text: 024-12013
Letter
United States securities and exchange commission logo June 5, 2024 Nick Bhargava Executive Vice President Groundfloor Finance Inc. 1201 Peachtree St NE, Suite 1104-400 Atlanta, GA 30361 Re:Groundfloor Finance Inc. Offering Statement on Form 1-A Post-qualification Amendment No. 7 Filed May 9, 2024 File No. 024-12013 Dear Nick Bhargava: We have reviewed your amendment and have the following comments. Please respond to this letter by amending your offering statement and providing the requested information. If you do not believe a 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 letter, we may have additional comments. Form 1-A POS filed May 9, 2024 General 1.We note your response to prior comment 1 and re-issue. We note that in the Project Summary description boxes you continue to refer to the September 22, 2023 PQA. Please revise to reference the most recent offering circular for the offering contemplated. 2.We note your response to prior comment 2 and partially re-issue. We note that the Project Summary continues to reference several LROs relating to the same property. Please revise to ensure your disclosure no longer refers to properties with multiple LROs are done as “subsequent draws." 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.
FirstName LastNameNick Bhargava Comapany NameGroundfloor Finance Inc. June 5, 2024 Page 2 FirstName LastName Nick Bhargava Groundfloor Finance Inc. June 5, 2024 Page 2 We remind you that the company and its management are responsible for the accuracy 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 Pam Howell at 202-551-3357 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Brian Korn
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United States securities and exchange commission logo
June 5, 2024
Nick Bhargava
Executive Vice President
Groundfloor Finance Inc.
1201 Peachtree St NE, Suite 1104-400
Atlanta, GA 30361
Re:Groundfloor Finance Inc.
Offering Statement on Form 1-A
Post-qualification Amendment No. 7
Filed May 9, 2024
File No. 024-12013
Dear Nick Bhargava:
We have reviewed your amendment and have the following comments.
Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a 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 letter, we may have additional comments.
Form 1-A POS filed May 9, 2024
General
1.We note your response to prior comment 1 and re-issue. We note that in the Project
Summary description boxes you continue to refer to the September 22, 2023 PQA. Please
revise to reference the most recent offering circular for the offering contemplated.
2.We note your response to prior comment 2 and partially re-issue. We note that the Project
Summary continues to reference several LROs relating to the same property. Please revise
to ensure your disclosure no longer refers to properties with multiple LROs are done as
“subsequent draws."
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.
FirstName LastNameNick Bhargava
Comapany NameGroundfloor Finance Inc.
June 5, 2024 Page 2
FirstName LastName
Nick Bhargava
Groundfloor Finance Inc.
June 5, 2024
Page 2
We remind you that the company and its management are responsible for the accuracy
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 Pam Howell at 202-551-3357 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Brian Korn