SEC Company Response from WORLD TREE USA, LLC (CIK 0001687316) — Jun 25, 2020
WORLD TREE USA, LLC (CIK 0001687316)
Date: June 25, 2020 · CIK: 0001687316 · Accession: 0001477932-20-003567
AI Filing Summary & Sentiment
File numbers found in text: 024-11051
Referenced dates: June 11, 2020
Letter
Via EDGAR United States Securities and Exchange Commission Division of Corporate Finance Re: World Tree USA, LLC Post-Qualification Amendment No. 4 to Offering Statement on Form 1-A Filed May 28, 2020 File No. 024-11051
Dear Mr. Gabor:
In response to your letter dated June 11, 2020, concerning the deficiencies in our offering statement on Form 1-A, we provide the following responses:
Post-Qualification Amendment No. 4 to Offering Statement on Form 1-A
General
1. We note that you intend to offer the first two million units for $1.25 per unit and the remaining five million units for $1.50 per unit, which is not permitted under Regulation A. Please revise your offering statement to offer the units at one fixed price for the duration of the offering. Refer to Rule 251(d)(3)(ii) of Regulation A for further guidance. If you change the offering price in the future, you should announce any price changes in either a post-qualification amendment or supplement, depending on the facts and circumstances at the time of the change. Please refer to Rule 252(f)(2)(ii) and Rule 253(g)(2) of Regulation A for further guidance.
ANSWER:
We have revised our offering statement to offer the units at one fixed price ($1.50 per unit).
We understand that FINRA must advise the SEC that it has no objections to the compensation arrangements prior to qualification.
Yours truly,
/s/ Wendy Burton
Wendy Burton, Founder and Chair
Show Raw Text
CORRESP 1 filename1.htm wtcu_corresp.htm June 25, 2020 Via EDGAR Attn: Jeffrey Gabor, Attorney-Advisor United States Securities and Exchange Commission Division of Corporate Finance 100 F Street, NE Washington, DC 20549-4561 Re: World Tree USA, LLC Post-Qualification Amendment No. 4 to Offering Statement on Form 1-A Filed May 28, 2020 File No. 024-11051 Dear Mr. Gabor: In response to your letter dated June 11, 2020, concerning the deficiencies in our offering statement on Form 1-A, we provide the following responses: Post-Qualification Amendment No. 4 to Offering Statement on Form 1-A General 1. We note that you intend to offer the first two million units for $1.25 per unit and the remaining five million units for $1.50 per unit, which is not permitted under Regulation A. Please revise your offering statement to offer the units at one fixed price for the duration of the offering. Refer to Rule 251(d)(3)(ii) of Regulation A for further guidance. If you change the offering price in the future, you should announce any price changes in either a post-qualification amendment or supplement, depending on the facts and circumstances at the time of the change. Please refer to Rule 252(f)(2)(ii) and Rule 253(g)(2) of Regulation A for further guidance. ANSWER: We have revised our offering statement to offer the units at one fixed price ($1.50 per unit). We understand that FINRA must advise the SEC that it has no objections to the compensation arrangements prior to qualification. Yours truly, /s/ Wendy Burton Wendy Burton, Founder and Chair