SEC Comment Letter for Legion Capital Corp (LGCP) (CIK 0001661166) — Apr 1, 2020
Legion Capital Corp (LGCP) (CIK 0001661166)
Date: April 1, 2020 · CIK: 0001661166 · Accession: 0000000000-20-002806
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File numbers found in text: 024-11123
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April 1, 2020
James S. Byrd, Jr.
Chief Executive Officer
Legion Capital Corporation
301 E. Pine Street
Suite 850
Orlando, FL 32801
Re:Legion Capital Corporation
Post-Qualification Amendment No. 1 to
Offering Statement on Form 1-A
Filed March 20, 2020
File No. 024-11123
Dear Mr. Byrd:
We have reviewed your amendment and do not have any comments.
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.
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.
You may contact Michael Volley, Staff Accountant, at (202) 551-3437 or Amit Pande,
Accounting Branch Chief, at (202) 551-3423 if you have questions regarding comments on the
financial statements and related matters. Please contact J. Nolan McWilliams, Attorney-
Advisor, at (202) 551-3217 or Justin Dobbie, Legal Branch Chief, at (202) 551-3469 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Finance