SEC Comment Letter 0000000000-23-007322 to Chase Card Funding LLC (CIK 0001658982)
Chase Card Funding LLC (CIK 0001658982)
Date: July 10, 2023 · CIK: 0001658982 · Accession: 0000000000-23-007322
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File numbers found in text: 333-272941
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United States securities and exchange commission logo
July 10, 2023
Simon Braeutigam
Chief Executive Officer
Chase Card Funding LLC
201 North Walnut Street
Wilmington, DE 19801
Re:Chase Card Funding LLC
Chase Issuance Trust
Registration Statement on Form SF-3
Filed June 26, 2023
File Nos. 333-272941 and 333-272941-01
Dear Simon Braeutigam:
We have limited our review of your registration statement to those issues we have
addressed in our 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 comments.
Registration Statement on Form SF-3
General
1.We note your disclosure throughout the registration statement regarding existing and
future collateral certificates. Please register any collateral certificates that have been or
may be acquired by the issuing entity in connection with the offering of the asset-backed
securities. Refer to Section III.A.6 of Release No. 33-8518 (Dec. 22, 2004) and Rule
190(c) and (d) under the Securities Act. Please provide placeholder disclosure regarding
the issuance and characteristics of the collateral certificates being registered, as
appropriate.
FirstName LastNameSimon Braeutigam
Comapany NameChase Card Funding LLC
July 10, 2023 Page 2
FirstName LastName
Simon Braeutigam
Chase Card Funding LLC
July 10, 2023
Page 2
2.To the extent there are currently no existing collateral certificates held by the issuing
entity, and no collateral certificates are being registered on this registration statement,
please revise your disclosure to remove references to existing collateral certificates.
Similarly, to the extent future collateral certificates are not being registered prior to the
effectiveness of this registration statement, please revise your disclosure to remove
references to the ability to include future collateral certificates. Without registration prior
to effectiveness, such securities can only be offered upon the effectiveness of a new
registration statement registering such securities; therefore, disclosure regarding the
issuance of such securities would not be relevant to this registration statement. Refer to
Rule 413 under the Securities Act.
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Jason Weidberg at 202-551-6892 or Arthur Sandel at 202-551-3262 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Structured Finance