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SEC Comment Letter for MasterCraft Boat Holdings, Inc. (MCFT) (CIK 0001638290) (MCFT) — Jul 2, 2015

MasterCraft Boat Holdings, Inc. (MCFT) (CIK 0001638290)
Date: July 2, 2015 · CIK: 0001638290 · Accession: 0000000000-15-034747

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 333-203815

Date
May 1, 2015
Author
/s/ Justin Dobbie
Form
UPLOAD
Company
MasterCraft Boat Holdings, Inc. (MCFT) (CIK 0001638290)

Letter

July 2 , 201 5 Terry McNew Chief Executive Officer MCBC Holdings , Inc. 100 Cherokee Cove Drive Vonore, TN 37885

Re: MCBC Holdings , Inc. Amendment No. 3 to Registration Statement on Form S-1 Filed June 25, 201 5 File No. 333-203815

Dear Mr. McNew :

We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional commen ts.

Signatures, page II -4

1. Please have Mr. Campion sign the regis tration statement. We note that he did not sign the initial filing on May 1, 2015 that included the power of attorney.

Exhibits

2. Please refile a legible copy of Exhibit 10.3.

3. We note your disclosure that the company entered into new employment agreement s with each of the named executive officers effective as of July 1, 2015. Please refile exhibits 10.14, 10.15 and 10.16 to include the conformed signatures for each of the new employment agreements.

Terry McNew MCBC Holdings , Inc. July 2 , 201 5 Page 2

You may contact Melissa Gilmore at (202) 551 -3777 or Andrew Mew at (202) 551 -3377 if you have questions regarding comments on the financial statements and related matters. Please contact Ada D. Sarmento at (202) 551 -3798 or me at (202) 551 -3469 with any other questions.

Sincerely,
/s/ Justin Dobbie

Show Raw Text
July 2 , 201 5

Terry McNew
Chief Executive  Officer
MCBC Holdings , Inc.
100 Cherokee Cove Drive
Vonore, TN 37885

Re: MCBC Holdings , Inc.
  Amendment No. 3  to Registration Statement on Form  S-1
Filed  June  25, 201 5
  File No.  333-203815

Dear Mr. McNew :

We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information.   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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional commen ts.

Signatures, page II -4

1. Please have Mr. Campion sign the regis tration statement.  We note that he did not sign
the initial filing on May 1, 2015 that included the power of attorney.

Exhibits

2. Please refile a legible copy of Exhibit 10.3.

3. We note your disclosure that the company entered into new employment agreement s with
each of the named executive officers effective as of July 1, 2015.  Please refile exhibits
10.14, 10.15 and 10.16 to include the conformed signatures for each of the new
employment agreements.

Terry McNew
MCBC Holdings , Inc.
July 2 , 201 5
Page 2

You may contact  Melissa Gilmore  at (202) 551 -3777 or Andrew Mew  at (202) 551 -3377
if you have questions regarding comments on the financial statements and related matters.
Please contact Ada D. Sarmento  at (202) 551 -3798 or me at (202) 551 -3469 with any other
questions.

Sincerely,

 /s/ Justin Dobbie

Justin Dobbie
Legal Branch Chief

cc:  Kirk A. Davenport  II, Esq.