SEC Comment Letter for WORLD TREE USA, LLC (CIK 0001687316) — Apr 8, 2020
WORLD TREE USA, LLC (CIK 0001687316)
Date: April 8, 2020 · CIK: 0001687316 · Accession: 0000000000-20-003041
AI Filing Summary & Sentiment
File numbers found in text: 024-11051
Letter
April 8, 2020 Wendy Burton Founder & Chair of the Manager World Tree USA, LLC 1910 South Stapley Dr., Suite 221 Mesa, AZ 85204 Re:World Tree USA, LLC Post-Qualification Amendment No. 1 to Offering Statement on Form 1-A Filed March 12, 2020 File No. 024-11051 Dear Ms. Burton: We have reviewed your amendment and have the following comment. Please respond to this letter by amending your offering statement and providing the requested information. If you do not believe our comment applies 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 offering statement and the information you provide in response to this comment, we may have additional comments. Post-Qualification Amendment No. 1 to Offering Statement on Form 1-A Part F/S Unaudited Financial Statements, page F-1 1.Your unaudited financial information for the twelve months ended December 31, 2019 does not include footnotes, and, as such, is not complete. Revise to provide updated audited financial statements for the year ended December 31, 2019 with complete footnotes. Refer the guidance in “Part FS” for Tier 2 filings within Form 1-A. 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.
FirstName LastNameWendy Burton Comapany NameWorld Tree USA, LLC April 8, 2020 Page 2 FirstName LastName Wendy Burton World Tree USA, LLC April 8, 2020 Page 2 You may contact Franklin Wyman at 202-551-3660 or Kevin Vaughn at 202-551-3494 if you have questions regarding comments on the financial statements and related matters. Please contact Jeffrey Gabor at 202-551-2544 or Ada Sarmento at 202-551-3798 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Shelly Befumo
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April 8, 2020
Wendy Burton
Founder & Chair of the Manager
World Tree USA, LLC
1910 South Stapley Dr., Suite 221
Mesa, AZ 85204
Re:World Tree USA, LLC
Post-Qualification Amendment No. 1 to Offering Statement on Form 1-A
Filed March 12, 2020
File No. 024-11051
Dear Ms. Burton:
We have reviewed your amendment and have the following comment.
Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe our comment applies 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 offering statement and the information you
provide in response to this comment, we may have additional comments.
Post-Qualification Amendment No. 1 to Offering Statement on Form 1-A
Part F/S
Unaudited Financial Statements, page F-1
1.Your unaudited financial information for the twelve months ended December 31, 2019
does not include footnotes, and, as such, is not complete. Revise to provide updated
audited financial statements for the year ended December 31, 2019 with complete
footnotes. Refer the guidance in “Part FS” for Tier 2 filings within Form 1-A.
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.
FirstName LastNameWendy Burton
Comapany NameWorld Tree USA, LLC
April 8, 2020 Page 2
FirstName LastName
Wendy Burton
World Tree USA, LLC
April 8, 2020
Page 2
You may contact Franklin Wyman at 202-551-3660 or Kevin Vaughn at 202-551-3494 if
you have questions regarding comments on the financial statements and related matters. Please
contact Jeffrey Gabor at 202-551-2544 or Ada Sarmento at 202-551-3798 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Shelly Befumo