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SEC Comment Letter for MasterCraft Boat Holdings, (MCFT) — Aug 5, 2016

MasterCraft Boat Holdings, Inc.
Date: Aug. 5, 2016 · CIK: 0001638290 · Accession: 0000000000-16-087381

AI Filing Summary & Sentiment

File numbers found in text: 333-212812

Date
August 5, 2016
Author
/s/ Justin Dobbie
Form
UPLOAD
Company
MasterCraft Boat Holdings, Inc.

Letter

Mail Stop 3561 August 5, 2016 Terry McNew President and Chief Executive Officer MCBC Holdings, Inc. 100 Cherokee Cove Drive Vonore, TN 37885

Re: MCBC Holdings, Inc. Registration Statement on Form S-3 Filed August 1, 2016 File No. 333-212812

Dear Mr. McNew :

This is to advise you that we have not reviewed and will not review your registration statement .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h respect to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and

 the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Terry McNew MCBC Holdings, Inc. August 5, 2016 Page 2

Please refer to Rules 460 and 4 61 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities u nder the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .

Please contact Julie Griffith at 202-551-3267 with any questions.

Sincerely,
/s/ Justin Dobbie

Show Raw Text
Mail Stop 3561

August 5, 2016

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

Re: MCBC Holdings, Inc.
  Registration Statement on Form S-3
Filed  August 1, 2016
  File No.  333-212812

Dear Mr. McNew :

This is to advise you that we have not  reviewed and will not review your registration
statement .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are  in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In the event you request acceleration of the effective date of the pending regist ration
statement , please provide  a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action wit h respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in th e filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Terry McNew
MCBC Holdings, Inc.
August 5, 2016
Page 2

 Please refer to Rules 460 and 4 61 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities u nder
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities .

Please  contact Julie Griffith  at 202-551-3267  with any questions.

Sincerely,

 /s/ Justin Dobbie

Justin Dobbie
Legal Branch Chief
Office of Transportation and Leisure