SEC Comment Letter 0000000000-23-001197 to Monetiva Inc. (CIK 0001681309)
Monetiva Inc. (CIK 0001681309)
Date: Feb. 6, 2023 · CIK: 0001681309 · Accession: 0000000000-23-001197
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File numbers found in text: 333-269171
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United States securities and exchange commission logo
February 6, 2023
Pierre Sawaya
President
Monetiva Inc.
23615 El Toro Rd., Suite X327
Lake Forest, CA 92630
Re:Monetiva Inc.
Registration Statement on Form S-1
Filed January 10, 2023
File No. 333-269171
Dear Pierre Sawaya:
We have reviewed your 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 comments.
Form S-1 filed January 10, 2023
Business and Properties
Our Current Business, page 29
1.We note your disclosure that you are a start-up company in the developmental phase of
the business cycle except in the U.S. which is already developed and that USA is
established. We also note your disclosure that you expect to conclude Phase I of your
business plan in Winter 2023. Please explain clearly what you mean by USA is
established and already developed in the United States, given the status of Phase I of your
business plan. Also, explain clearly what you mean by Mexico is under process, and India
is still under way.
FirstName LastNamePierre Sawaya
Comapany NameMonetiva Inc.
February 6, 2023 Page 2
FirstName LastName
Pierre Sawaya
Monetiva Inc.
February 6, 2023
Page 2
2.We note your disclosure on page 1 regarding the upfront fees payable under the terms of
the Processing Service Agreement with EndlessOne Global, Inc. Please tell us whether
there are any other material fees payable under that agreement and provide disclosure, as
appropriate. Also, clarify the current relationship between Pierre Sawaya and EndlessOne
Global, Inc.
3.We note that certain portions of Exhibit 10.3 have been redacted. Pursuant
to Item 601(b)(10)(iv), please revise your exhibit index to reflect that certain information
has been excluded from these exhibits.
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.
You may contact Mark Rakip at 202-551-3573 or Shannon Menjivar at 202-551-3856 if
you have questions regarding comments on the financial statements and related matters. Please
contact Ruairi Regan at 202-551-3269 or Jeffrey Gabor at 202-551-2544 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Brian Higley, Esq.