SEC Comment Letter for FTAI Aviation Ltd. (FTAI, FTAIM, FTAIN, FTAIO) (CIK 0001590364) (FTAI) — Nov 3, 2014
FTAI Aviation Ltd. (FTAI, FTAIM, FTAIN, FTAIO) (CIK 0001590364)
Date: Nov. 3, 2014 · CIK: 0001590364 · Accession: 0000000000-14-054597
AI Filing Summary & Sentiment
File numbers found in text: 333-193182
Letter
November 3, 2014 Via e -mail Cameron D. MacDougal l Vice President Fortress Transportation and Infrastructure Investors LLC 1345 Avenue of the Americas, 46th Floor New York, New York 10105
Re: Fortress Transportation and Infrastructure Investors Ltd. Amendment No. 2 to Registration Statement on Form S -1 Filed October 8, 2014 File No. 333-193182
Dear Mr. MacDouga ll:
We have reviewed your registration statement and have the following comment .
Summary Historical Consolidated Financial Data, page 19
1. We note your disclosure on page 18 stating that Holdco was formed on May 9, 2011 and commenced operations on June 23, 2011. Further, we note your disclosure under this heading that the summary consolidated statement of operations data for the years ended December 31, 2013 and 2012, and the period from June 23, 2011 (commencement of operations) to December 31, 2011, and the summary consolidated balance sheet data as of December 31, 2013, 2012, and 2011 have been derived from your audited financial statements . However, no financial information for 2011 is included. Please revise your filing to include audited financial information in your filing for the period June 23, 2011 through December 31, 2011 in accordance with Rule 3 -02(a) of Regulation S -X, or tell us why you believe this does not apply to you.
You may c ontact Tracie Towner at (202) 551 -3744 or Alfred Pavot at (202) 551 -3738 if you have questions regarding comments on the financial statements and re lated matters. Please contact Leland Benton at (202) 551 -3791 or me at (202) 551 -3397 with any other questions.
Sincerely,
/s/ Jay Ingram
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November 3, 2014 Via e -mail Cameron D. MacDougal l Vice President Fortress Transportation and Infrastructure Investors LLC 1345 Avenue of the Americas, 46th Floor New York, New York 10105 Re: Fortress Transportation and Infrastructure Investors Ltd. Amendment No. 2 to Registration Statement on Form S -1 Filed October 8, 2014 File No. 333-193182 Dear Mr. MacDouga ll: We have reviewed your registration statement and have the following comment . Summary Historical Consolidated Financial Data, page 19 1. We note your disclosure on page 18 stating that Holdco was formed on May 9, 2011 and commenced operations on June 23, 2011. Further, we note your disclosure under this heading that the summary consolidated statement of operations data for the years ended December 31, 2013 and 2012, and the period from June 23, 2011 (commencement of operations) to December 31, 2011, and the summary consolidated balance sheet data as of December 31, 2013, 2012, and 2011 have been derived from your audited financial statements . However, no financial information for 2011 is included. Please revise your filing to include audited financial information in your filing for the period June 23, 2011 through December 31, 2011 in accordance with Rule 3 -02(a) of Regulation S -X, or tell us why you believe this does not apply to you. You may c ontact Tracie Towner at (202) 551 -3744 or Alfred Pavot at (202) 551 -3738 if you have questions regarding comments on the financial statements and re lated matters. Please contact Leland Benton at (202) 551 -3791 or me at (202) 551 -3397 with any other questions. Sincerely, /s/ Jay Ingram Jay Ingram Branch Chief