SEC Company Response from Velocity Financial, Inc. (VEL) (CIK 0001692376) (VEL) — Jan 14, 2020
Velocity Financial, Inc. (VEL) (CIK 0001692376)
Date: Jan. 14, 2020 · CIK: 0001692376 · Accession: 0001193125-20-007132
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File numbers found in text: 333-234250
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CORRESP
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filename1.htm
CORRESP
Simpson Thacher & Bartlett LLP
2475 HANOVER STREET
PALO ALTO, CA 94304
TELEPHONE:
+1-650-251-5000
FACSIMILE:
+1-650-251-5002
Direct Dial Number
+1-650-251-5095
E-mail Address
dwebb@stblaw.com
VIA EDGAR
January 14, 2020
Re:
Acceleration Request for Velocity Financial, LLC
Registration Statement on Form S-1 (File No. 333-234250)
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Stacie Gorman
Folake Ayoola
Ladies and Gentlemen:
Pursuant to Rule 461
under the Securities Act of 1933, as amended, we attach the requests of our client, Velocity Financial, LLC, and of the underwriters that effectiveness of the above-referenced Registration Statement be accelerated to 2:00 p.m., Eastern Time, on
January 16, 2020, or as soon as practicable thereafter. We ask, however, that the Securities and Exchange Commission staff not accelerate such effectiveness until we speak with you on that date.
Call me at (650) 251-5095 with any questions.
Very truly yours,
/s/ Daniel N. Webb
Daniel N. Webb
NEW YORK BEIJING HONG KONG
HOUSTON LONDON LOS ANGELES SÃO PAULO TOKYO
WASHINGTON, D.C.
January 14, 2020
VIA EDGAR AND EMAIL
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Stacie Gorman
Folake Ayoola
Re:
Velocity Financial, LLC
Registration Statement on Form S-1
Submitted January 6, 2020
File No. 333-234250
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), Velocity Financial, LLC (the
“Company”) hereby requests acceleration of the effectiveness of the above-referenced Registration Statement on Form S-1, as amended by Amendment No. 2 thereto, so that it will become
effective at 2:00 p.m., Eastern Time, on January 16, 2020, or as soon as possible thereafter. In this regard, the Company is aware of its obligations under the Securities Act.
Please contact Dan Webb (650-251-5095) of Simpson
Thacher & Bartlett LLP with any questions you may have regarding this request. In addition, please notify Mr. Webb by telephone when this request for acceleration has been granted.
[Signature Page Follows]
Very truly yours,
VELOCITY FINANCIAL, LLC
By:
/s/ Christopher Farrar
Name: Christopher Farrar
Title: Chief Executive Officer
cc:
Securities and Exchange Commission
January 14, 2020
Securities and Exchange Commission
Division of Corporation
Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn:
Stacie Gorman
Folake Ayoola
Re:
Request for Acceleration of Effectiveness
Velocity Financial, LLC
Registration Statement on Form S-1
(File No. 333-234250)
Ladies and Gentlemen:
In connection with the
above-referenced Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), as representatives of the several underwriters we hereby join in the request of Velocity Financial, LLC (the
“Company”) that the effective date of the above-referenced Registration Statement be accelerated so that it will be declared effective at 2:00 p.m., Eastern Time, on January 16, 2020, or as soon thereafter as practicable, or at such
other time as the Company or its outside counsel, Simpson Thacher & Bartlett LLP, request by telephone that such Registration Statement be declared effective.
The following is supplemental information supplied under Rule 418(a)(7) and Rule 460 under the Act:
(i) A preliminary prospectus dated January 6, 2020 (the “Preliminary Prospectus”) was distributed; no preliminary prospectuses
of a different date were distributed.
(ii) Dates of distribution: January 6, 2020 through the date hereof.
(iii) A total of approximately 1,425 copies of the Preliminary Prospectus were distributed to prospective underwriters, institutional
investors, dealers and others.
(iv) We, the undersigned, as representatives of the several underwriters, advise you that we have complied
and will continue to comply, and we have been informed by the participating underwriters that they have complied and will continue to comply, with Rule 15c2-8 under the Securities Exchange Act of 1934, as
amended.
[Signature Page Follows]
Very truly yours,
WELLS FARGO SECURITIES, LLC
By:
/s/ Lear Beyer
Name:
Lear Beyer
Title:
Managing Director
CITIGROUP GLOBAL MARKETS INC.
By:
/s/ Ian Wesson
Name:
Ian Wesson
Title:
Managing Director
JMP SECURITIES LLC
By:
/s/ Thomas Kilian
Name:
Thomas Kilian
Title:
COO – Investment Banking