SEC Company Response from Legion Capital Corp (LGCP) (CIK 0001661166) — Jul 6, 2022
Legion Capital Corp (LGCP) (CIK 0001661166)
Date: July 6, 2022 · CIK: 0001661166 · Accession: 0001213900-22-037549
AI Filing Summary & Sentiment
File numbers found in text: 024-11123
Referenced dates: June 29, 2022
Letter
United States Securities and Exchange Commission Washington, DC Re: Legion Capital Corporation Post Qualification Amendment No. 10 to Form 1-A Filed June 21, 2022 File No. 024-11123
Dear Messrs. Stickel and McWilliams,
Legion Capital is in receipt of your Comment Letter dated June 29, 2022 and responds to same as follows:
Post Qualification Amendment No. 10 to Form 1-A
General
1. We note that you filed the Form 1-K for the fiscal year ended December 31, 2021 on June 16, 2022. Per Rule 257(b)(1) of Regulation A and General Instruction A(2) of Form 1-K, annual reports shall be filed within 120 calendar days after the end of the fiscal year covered by the report. Please tell us whether offers and sales were made while your Offering Statement was not current, and if so provide your detailed analysis how any offers and sales complied with Regulation A and were not made in violation of Section 5 of the Securities Act of 1933. Refer to Rule 252(f)(2)(ii) of Regulation A.
Response:
The Company did not make any offers or sales during the delinquency period. There were a number of transactions that were either pending or en route to our transfer agent, Securities Transfer Corp (STC), at the time the Company became delinquent. As a result, Subscription Agreements and funds were held by STC during the period of delinquency. The Company did not accept any Subscriptions or receive or otherwise make use of any funds during the period of delinquency.
Once the Company filed its 1-K and was no longer delinquent, those transactions were accepted and closed.
By: /s/ Paul Carrazzone
Paul Carrazzone
President and CEO
Show Raw Text
CORRESP
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LEGION CAPITAL CORPORATION
301 E. PINE ST., STE. 850
ORLANDO, FL. 32801
July 6, 2022
Mr. John Stickel
Mr. J. Nolan McWilliams
United States Securities and Exchange Commission
Washington, DC
Re:
Legion Capital Corporation
Post Qualification Amendment No. 10 to Form 1-A Filed June 21, 2022
File No. 024-11123
Dear Messrs. Stickel and McWilliams,
Legion Capital is in receipt of your Comment Letter
dated June 29, 2022 and responds to same as follows:
Post Qualification Amendment No. 10 to Form 1-A
General
1. We note that you filed the Form 1-K for
the fiscal year ended December 31, 2021 on June 16, 2022. Per Rule 257(b)(1) of Regulation A and General Instruction A(2) of Form
1-K, annual reports shall be filed within 120 calendar days after the end of the fiscal year covered by the report. Please tell us
whether offers and sales were made while your Offering Statement was not current, and if so provide your detailed analysis how any
offers and sales complied with Regulation A and were not made in violation of Section 5 of the Securities Act of 1933. Refer to Rule
252(f)(2)(ii) of Regulation A.
Response:
The
Company did not make any offers or sales during the delinquency period. There were a number of transactions that were either pending
or en route to our transfer agent, Securities Transfer Corp (STC), at the time the Company became delinquent. As a result,
Subscription Agreements and funds were held by STC during the period of delinquency. The Company did not accept any Subscriptions or
receive or otherwise make use of any funds during the period of delinquency.
Once the Company filed its 1-K and was no
longer delinquent, those transactions were accepted and closed.
By:
/s/ Paul Carrazzone
Paul Carrazzone
President and CEO